Consultant payments and a French-company resolution
DOJ’s March 19, 2026 announcement describes two different outcomes from a foreign-bribery investigation: a corporate declination for Balt and an indictment of two individuals. The distinction matters when assessing what the announcement establishes.
Enforcement · 09 Oct 2026
A corporate resolution and separate allegations
DOJ declined to prosecute French medical-device company Balt, which agreed to approximately $1.2 million in disgorgement. The announcement also described a coordinated resolution with French authorities. DOJ credited Balt’s voluntary disclosure, cooperation and remediation, among other factors described below. This reported outcome does not promise the same treatment for another company.
Separately, DOJ reported charges against Individual 1 (an executive at Balt’s U.S. subsidiary) and Individual 2 (a consultant hired by that subsidiary). Prosecutors alleged that payments described as consulting fees and bonuses funded bribes to a physician at a state-owned French hospital to influence purchases of Balt products. The alleged concealment included sham consulting agreements, fake invoices and personal email accounts.
The indictment is an allegation. The individuals are presumed innocent unless proven guilty beyond a reasonable doubt. The corporate resolution does not establish their guilt.
Factors DOJ cited
DOJ said its declination of Balt under Part I of the Corporate Enforcement Policy (CEP) reflected seven factors:
- Timely and voluntary self-disclosure of misconduct identified during an internal investigation that was still ongoing when Balt disclosed.
- Full and proactive cooperation, including all known relevant facts and information about the individuals involved, and an agreement to keep cooperating with ongoing DOJ investigations and any resulting prosecutions.
- The nature and seriousness of the offense.
- Timely and appropriate remediation: disciplinary action against relevant personnel, termination of the business relationships that gave rise to the misconduct, tailored compliance training for senior management and improvements to its compliance program and internal controls.
- The absence of aggravating circumstances that, weighed against the disclosure, cooperation and remediation, would warrant a different disposition.
- Acceptance of responsibility and a parallel resolution with French authorities, which will include corporate compliance requirements under the French system.
- An agreement to disgorge the gains from the misconduct.
Questions for intermediary oversight
The allegations raise practical questions for companies using intermediaries: what service does a payment buy, who ultimately receives the funds, and what evidence supports an invoice? A contract description alone may leave those questions unanswered.
The remediation measures listed above are what DOJ reported in this case, not a checklist guaranteeing a declination. This article does not independently interpret the CEP or provide healthcare regulatory advice.
For questions about corporate compliance controls, contact Zimmermann Law.
Sources: Justice Department Resolves Foreign Bribery Investigation with Balt SAS; Healthcare Executive and Sales Consultant Indicted in Alleged Years-Long Foreign Bribery Scheme
This post is for general information and is not legal advice.
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