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Pharma FCPA Rewards: Trips, Entertainment, Gifts, and Personal Services - Dodd-Frank Rewards
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This is FCPA Whistleblower clipart.People who report healthcare companies bribing government doctors or officials may be eligible for a reward under the Dodd-Frank program. In addition to making payments to government officials, pharma often bribes government doctors by providing them trips, entertainment, gifts, and personal services.

This is part four in a series that is examining international pharma corruption and how to identify potential reward eligible information. The first post in this series examined the many ways pharma pays key opinion leaders (KOLs) and doctors, the second post discussed pharma’s bribery of regulatory officials, and the third post addressed pharma’s hiring of doctors, their relatives, and their businesses. This post will examine how pharma often bribes government doctors and officials by giving them trips, entertainment, gifts, and personal favors and services. Whether you are a pharma employee, a former pharma employee, or someone who is affiliated with the pharma sector, almost anyone can be a Dodd-Frank pharma whistleblower.  But to do so, it is helpful to understand where the bodies are buried and what information would be most helpful to regulators.

Trips: International, Local, and Corrupt Use of Travel Agencies

One of pharma’s most used bribery schemes is to offer KOLs and doctors international and local trips under the guise of educational conferences in return for prescribing their companies’ products and ensuring that their products are placed on the hospital formularies. Pharma’s marketing and sales will select which doctors receive the trips and discuss what they can expect to receive from the doctors in return for the trips. Travel agencies are often used to provide doctors cash or “pocket money” in connection with the trips. In one case, the travel agency would issue doctors refundable business class tickets wherein the doctors would cash in the expensive tickets and pocket the money.

Entertainment: Golf, Event Tickets, Shopping, Spas, and Vacation Houses

In addition to trips, pharma also uses entertainment to bribe KOLs and doctors. Below are a few examples:

  • Use of Vacation House:  In one case, a sales manager would make available his vacation house for a KOL and his family to use whenever they wanted. In return, that KOL only prescribed the sales manager’s products even though there was a much cheaper generic available.
  • Golfing and Tickets to Sporting Events and Concerts: In another instance, medical representatives would take certain doctors golfing and provide them tickets to sporting events and concerts in return for increased prescriptions.
  • Shopping and Spa Day: One particular case involved a sales representative taking a high-prescribing female doctor on a lavish shopping spree where the sales representative bought the doctor very expensive shoes and then took her for a full day spa treatment.
  • Strippers and Karaoke: In one memorable case from Asia, certain KOLs were taken to karaoke and strip clubs by medical representatives.

If anyone is aware of potentially lavish or inappropriate entertainment being provided to doctors, hospital administrators, or any government official, then please feel free to contact me for a free consultation.

Gifts, Personal Services, and Favors

Pharma uses gifts to bribe doctors. There have been cases involving pharma providing iPads, laptops, watches, and furniture to doctors. Pharma also has provided doctors personal services and favors to win business from doctors. There are cases involving medical representatives picking up doctors’ children from school, providing nanny services, and performing landscaping and yard maintenance for doctors. Other cases involve doctors requesting pharma to pay for their continuing medical education classes or hiring their children for internships.

If anyone has information about any SEC-regulated company (or one of its local affiliates, subsidiaries, or agents) being involved in providing trips, entertainment, gifts, favors, or personal services to doctors and would like to discuss making a confidential or anonymous submission under the Dodd-Frank program, please feel free to contact me at arickman@rickmanlegal.com for a free consultation. For more information and details about how the reward program applies to FCPA whistleblowers, please click here.


Andy Rickman is an SEC whistleblower attorney who has filed FCPA reward submissions for international clients residing in more than 50 different countries. He is based in Washington, DC where Dodd-Frank reward submissions are filed and the SEC is headquartered. Mr. Rickman offers a free consultation to anyone who would like to discuss whether he or she has a Dodd-Frank reward eligible case. Please feel free to contact him at arickman@rickmanlegal.com.