Rick Hartunian, partner, was featured in the Anti-Corruption Report article “Balt Settlement: International Cooperation Continues,” which examined the coordinated anti-corruption resolutions involving French medical device company Balt SAS and highlighted the continuing cooperation between US and French enforcement authorities despite evolving global enforcement priorities.
The article analyzed parallel resolutions by the US Department of Justice and Parquet national financier (PNF) arising from bribery allegations tied to Balt’s US subsidiary. The coordinated resolutions included a DOJ declination and a French Convention judiciaire d’intérêt public (CJIP), underscoring the increasing alignment between US and French anti-corruption enforcement practices.
Rick commented on the significance of the international coordination, telling the publication, “There appears to have been good communication and cooperation between the prosecutors in both countries.” He added that despite broader political tensions between the United States and France, “what happens on the grand stage is separate and apart from the work going on behind the scenes between professional prosecutors and law enforcement agencies working together.”
The article also explored lessons for companies navigating mergers and acquisitions involving potential anti-corruption risks. Rick noted that compensation structures rewarding aggressive revenue generation can create compliance concerns if not paired with appropriate safeguards. “One lesson may be that if a company has that kind of incentive compensation program it needs to have strong compliance controls in place so as to not incentivize corruption,” he said. He also emphasized the importance of “strong anti-corruption diligence built into the deal,” along with post-acquisition compliance measures such as training, invoice scrutiny, and oversight of communications practices.
Anti-Corruption Report subscribers can read the full article here.