Spain-based drug company Grifols disclosed in a recent securities filing that it is conducting an internal investigation across numerous countries in Europe and the Middle East into potential violations of the Foreign Corrupt Practices Act.

The investigation, which is being carried out by an external legal adviser, focuses on sales to certain Central and Eastern European countries, specifically Belarus and Russia. Trading practices in Brazil, China, Georgia, Iran, and Turkey are also being investigated, in addition to other countries “considered necessary,” the filing stated.

 

Grifols stated that the investigation began prior to the acquisition of biotherapeutics company Talecris, which had voluntarily informed the Department of Justice in 2009 of an internal investigation that the company was carrying out regarding potential violations of the FCPA concerning certain sales to certain central and East European countries.

As a result of this investigation, Grifols suspended shipments to some of these countries. In certain cases, Grifols had safeguards in place, which led to the suspension or termination of distributors in those countries under investigation “as circumstances warranted,” the filing stated. As a result of the investigation, the agreement with Talecris' Turkish distributor was terminated.

In 2012, the Justice Department notified Telecris that it was closing its proceedings related to any possible FCPA violations, with the caveat that proceedings could re-open in the future should new information arise. Grifols added that it “continues with the in-depth review of potential irregular practices.”