Corrupt practices in the US and UK healthcare industries

US regulators are aggressively pursuing enforcement actions against foreign companies and subsidiaries of US companies outside the US, in relation to practices that violate laws prohibiting corruption. The impact is particularly acute in relation to the pharma, biotech and medical device industries, because the regular business of companies in these industries involves contact with public hospitals and government health services. The extra-territorial effect of the US laws prohibiting corruption are evidenced by recent enforcement actions against pharma and medical device companies. This article examines the relevant UK legislation and the US Foreign Corrupt Practices Act, identifies high-risk areas for the healthcare industry and suggests potential solutions.