On December 22, 2016, Teva Pharmaceutical Industries Ltd. entered into a deferred prosecution agreement and its wholly owned Russian subsidiary Teva LLC agreed to plead guilty to conspiracy to violate the FCPA for a scheme to bribe government officials in Russia, Ukraine, and Mexico.  Between 2006 and at least 2012, Teva made corrupt payments to a high-ranking Russian government official, who then used his official position to influence the Russian government to purchase Copaxone, a multiple sclerosis drug.  In return, a Russian company that was owned and operated by the Russian official was granted the right to repackage and distribute Copaxone for sales to the Russian Ministry of Health.  Teva earned profits totaling approximately $204 million in sales made to the Russian government.  Teva also admitted to paying bribes to a senior official in the Ukrainian Ministry of Health in exchange for approval of Teva drug registrations required to enter the market in Ukraine, and Teva admitted to failing to implement adequate internal controls or enforce existing controls at its Mexican subsidiary.  As part of the resolution, Teva agreed to pay at least $519 to U.S. authorities—the largest ever FCPA resolution for a pharmaceutical company.  In addition to the guilty plea and DPA, Teva settled with the SEC, which filed a civil complaint in the Southern District of Florida, along with a consent judgment. Read more about this resolution in our client alertU.S. v. Teva LLC, No. 16-20967 (S.D. Fl.) DOJ Press Release