b'between 2010 and 2015, including Russia, Turkey,As furtherance of the bribery scheme, Alexion Turkey Brazil, and Colombia. The majority of the allegations,paid the consultant over $1.3 million from 2010 to 2015, however, stem from the conduct of two of Alexionsconsisting of consulting fees and purported expense foreign subsidiaries, Alexion Turkey and Alexion Russia,reimbursements; however, the consultant passed a and their efforts between 2010 and 2015 to influenceportion of these payments to Turkish government foreign officials to provide favorable regulatory treat- officials in the form of cash, meals, or gifts with the ment for Soliris. Alexion began commercial sales ofknowledge of Alexion Turkey employees. As a result of Soliris in 2007, after receiving approval to treat twothis scheme, the SEC found that Alexion was unjustly ultra-rare, life-threatening diseases. In Turkey, Alexionenriched by over $6.6 million. began selling Soliris via Turkeys named patient salesSimilar to its scheme in Turkey, Alexion Russia made program in 2009. Pursuant to Turkish law, Turkishpayments to Russian healthcare providers between healthcare providers had to approve each patients2011 and 2015 that amounted to over $1 million in application prior to taking Soliris. These same healthorder to influence the allocation of regional healthcare care providers were appointed to serve on commis- budgets for Soliris, increase the number of approved sions sponsored by Turkeys Ministry of Health. TheSoliris prescriptions, and favorably influence the SEC found that beginning in January 2010, during aregulatory treatment of Soliris. However, the payments period in which Alexion Turkey was struggling to sellin Russia were made directly, not through a third-party Soliris in Turkey, a senior Minister of Health officialintermediary. As one example, Alexion Russia made suggested to an Alexion Turkey regional accounthonoraria and research payments to Russian physi-manager that Alexion Turkey may need to makecians who could influence decision making in favor payments to government officials to obtain moreof Soliris. Much like Alexion Turkey, Alexion Russia patient approvals. Alexion Turkey followed the officialsinaccurately recorded these payments in its books advice and hired a consultant with connections toand records as various purported expenses, including top Ministry of Health officials to assist with the patientresearch and educational expenses. The SEC found approval process.that Alexion had knowledge of the risk of doing busi-ness in Russia, but it still failed to devise and maintain internal accounting controls. As a result of its scheme in Russia, Alexion admitted to being unjustly enriched by The SEC found that Alexion hadover $7.5 million. To resolve the investigation, Alexion agreed to pay knowledge of the risk of doing business$14.2 million in disgorgement, $3.76 million in prejudg-in Russia, but it still failed to devise andment interest, and a civil monetary penalty of $3.5 million. Alexion was also ordered to cease and desist maintain internal accounting controls. committing any violations of the FCPAs books and records and internal accounting controls provisions. 16'