“We are currently investigating whether certain business activities in a foreign country violated provisions of the Foreign Corrupt Practices Act (FCPA) and have engaged outside counsel to conduct this investigation,” Stryker said in the quarterly report. It did not provide any further details regarding the activities or country at issue.
Stryker added that it has been contacted by the Securities and Exchange Commission and the Department of Justice and is “cooperating with both agencies.”
In September 2018, Stryker agreed to pay a $7.8 million penalty to settle SEC charges that it violated the books and records and internal accounting controls provisions of the FCPA. In that case, the SEC’s order “found that Stryker’s internal accounting controls were not sufficient to detect the risk of improper payments in sales of Stryker products in India, China, and Kuwait, and that Stryker’s India subsidiary failed to maintain complete and accurate books and records.”
In October 2013, Stryker agreed to pay $13.2 million to settle SEC charges it violated the FCPA when subsidiaries in Argentina, Greece, Mexico, Poland, and Romania made approximately $2.2 million in bribery payments to doctors, health care professionals, and other government-employed officials in order to obtain or retain business. 
Jaclyn Jaeger is a contributing editor at Compliance Chief 360° and a freelance business writer based in Manchester, New Hampshire.