Alere, a public company that manufactures and sells diagnostic tests, has resolved SEC charges that it misstated its revenue and bribed government officials in Colombia and India. In the combined settlement, Alere agreed to pay $3.3 million in disgorgement, interest of about $495,000 and a penalty of $9.2 million. A DOJ investigation is still ongoing.
RK&O partner Audrey Laning Ingram gave her opinion on the Alere settlement to The Anti-Corruption Report saying, "The Alere settlement strikes me as a revenue-recognition case with an FCPA component rather than a traditional FCPA case. Alere serves as an important reminder about the ways in which government investigations may arise."