How to Implement Effective Internal Controls to Prevent Corrupt Behavior and Minimize the Risks of Third Party Bribes in Foreign Clinical Research

May 9, 2012

ACI 6th National Conference on FCPA and Anti-Corruption for the Life Sciences Industry
New York, New York

Bass, Berry & Sims FCPA and healthcare fraud attorney, John Kelly, will co-present “How to Implement Effective Internal Controls to Prevent Corrupt Behavior and Minimize the Risks of Third Party Bribes in Foreign Clinical Research” at the American Conference Institute’s 6th Annual Conference on FCPA and Anti-Corruption for the Life Sciences Industry. Co-presenters include Clivetty Martinez, Health Care Compliance & Privacy Johnson & Johnson International, Inc., and Joseph Alesia, Senior Counsel, Ethics and Compliance/Legal for Baxter International Inc.

The presentation will cover:

  • Best practices for monitoring actions undertaken by HCPs, CROs, third parties and other consultants when interacting with local government officials during the clinical research process
    • how to establish procedures for ensuring local procedures are followed without exposing the company to potential FCPA violations –
    • establishing internal controls to detect and prevent local anti-bribery issues, particularly within foreign clinical research, sales and distribution operations – investigator, health ministry approval, patient payments
  • Distinguishing parameters for locally-accepted/expected “grease payments” vs. what is permissible under the FCPA – knowing where to draw the line regarding what does/does not qualify as a facilitation payment
  • Striking the balance between too much vs. too little oversight when managing and overseeing operations led by local third parties
  • UK Bribery Act – how companies are updating global compliance programs to address facilitation payments across international life sciences operations

Bass, Berry & Sims is proud to be a sponsor of this conference.