DOJ Uses FCPA Case to Underscore Self-Disclosure Message

Posted 3/20/26

The Justice Department’s declination for Balt SAS and Balt USA LLC is emerging as an early test of the department’s revised corporate-enforcement framework, with compliance observers arguing the case shows DOJ is trying to reward companies that report misconduct before investigators arrive.

DOJ declined to prosecute the French medical-device company, required disgorgement of $1,214,797.  As well, the governement charged former Balt USA executive David Ferrera and Belgian consultant Marc Tilman over an alleged bribery scheme involving a physician at a French state-owned public hospital. 

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