In 2011 and 2012, the Obama administration’s Securities and Exchange Commission levied large penalties against U.S. pharmaceutical companies for violating the Foreign Corrupt Practices Act. These included Johnson & Johnson, Pfizer, and Eli Lilly and Company. Among the charges was making donations to a charitable foundation in Poland.
That charitable foundation was run by an official with a regional health ministry who had the authority to make pharmaceutical purchasing decisions. The charitable foundation was legitimate and the foundation’s work was for a good cause. But the U.S. government found that the donation still had a corrupt purpose.
Again, the Clinton foundation says the money was given for a good cause — earthquake relief in Haiti. At least when the shoe is on the other foot and U.S. companies are donating to foreign charities, the U.S. government does not hold the view that such donations toward charitable purposes can not be tainted.
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