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This is FCPA Whistleblower clipart.Pharma FCPA whistleblowers who report healthcare companies bribing government doctors or officials may be eligible for a reward under the Dodd-Frank program. Some of the ways pharma bribes government doctors and regulatory officials are by engaging them as consultants, hiring their family members, and engaging third-party entities affiliated with them.

This is part three 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 and doctors, and the second post discussed pharma’s bribery of regulatory officials. This post will examine how pharma often bribes government doctors and officials by engaging them as consultants, hiring their family members, and engaging doctor-affiliated vendors and suppliers. 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.

Pharma human resources personnel will often learn about management and government affairs hiring government doctors, regulatory officials, and/or their relatives. Frequently, government doctors and officials will request pharma to hire their relatives, and in return these officials will increase prescriptions, help ensure the company’s products are placed on the formulary, and will assist with any regulatory violations or issues, such as government pricing and reimbursement, the company is facing. In one matter, pharma hired government doctors to serve as “medical directors” and advise the company on strategic marketing issues. These same government doctors were the ones who made the decision on the company’s pricing and reimbursement rates for two of its key products. Pharmaceutical companies also often engage KOLs in “consulting” agreements where they pay them for creating and giving a presentation when they are truly being paid for prescribing the company’s products and helping ensure that their products are on the formularies.

Pharma procurement and purchasing personnel often will become aware if management or government affairs requests that a vendor or supplier be engaged that is affiliated with a government doctor or official. Many KOLs will seek sponsorships for certain conferences and events that they are putting on and will direct pharma as to which event companies should be paid. When doctors direct pharma as to which event companies and suppliers should be engaged, it is almost a certainty that the event companies in question are either owned or affiliated with the doctors in some way. Pharma is often happy to do whatever the doctors ask because they want those doctors to keep prescribing their products and helping ensure that their products remain on the formularies.

If anyone has information about any SEC-regulated company (or one of its local affiliates, subsidiaries, or agents) being involved in hiring doctors or their relatives or engaging third parties that are owned or affiliated with doctors or officials and would like to discuss making a confidential or anonymous submission under the Dodd-Frank program, please feel free to contact me at 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 FCPA whistleblower attorney who has filed SEC 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