Pfizer has resolved with the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) matters related to certain improper payments in the operations of two of its subsidiaries outside the United States.

A Pfizer subsidiary (Pfizer H.C.P. Corporation) will enter into a deferred prosecution agreement with the DOJ and pay a fine of $15 million. Under the terms of a civil settlement with the SEC, Pfizer agreed to a disgorgement of profits of $16 million and prejudgment interest of $10.3 million. The DOJ declined to bring a criminal action against Pfizer. The DOJ settlement with Pfizer H.C.P. Corporation covers improper conduct in Bulgaria, Croatia, Kazakhstan, and Russia. The Pfizer SEC civil settlement covers improper conduct in all of these countries as well as in Italy, China, the Czech Republic, and Serbia. As part of its agreement with the DOJ, Pfizer H.C.P. Corporation will continue to cooperate with the DOJ for a period of two years in connection with its settlement.

In a separate civil settlement with the SEC, Pfizer’s Wyeth subsidiary has agreed to a disgorgement of profits of $17.2 million and prejudgment interest of $1.66 million to resolve issues involving certain improper payments in the operations of four subsidiaries outside the US. Pfizer conducted a risk-based Foreign Corrupt Practices Act due-diligence review of Wyeth’s global operations after it acquired the company in late 2009, and voluntarily disclosed these issues to the US government, according to an Aug. 7, 2012, Pfizer press release. Pfizer’s postacquisition due diligence review of Wyeth identified certain improper payments in China, Saudi Arabia, Indonesia, and Pakistan.

“There is no allegation by either DOJ or SEC that anyone at Pfizer’s or Wyeth’s corporate headquarters knew of or approved the conduct at issue before Pfizer took appropriate action to investigate and report it, “ said Pfizer in its release. “As soon as these local activities came to the attention of Pfizer’s corporate headquarters, they were voluntarily brought to the attention of the DOJ and SEC. Today’s settlements are focused solely on these local activities.”

All the conduct at issue was investigated by Pfizer and voluntarily disclosed to the US government, according to the company. Pfizer began self-reporting to the US government in 2004 after the discovery of certain improper payments that had been made by employees of a recently acquired Pfizer affiliate in Croatia. Pfizer legal and compliance staff, outside counsel and auditors, conducted an internal investigation and regularly briefed DOJ and SEC on its findings, said Pfizer in its release.