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A study published in February 2026 in the Journal of Law, Medicine & Ethics is the first to compile decades of Organization for Economic Cooperation and Development (OECD) enforcement records into a single analysis. Researchers Kohler, Khan, and Bowra reviewed OECD Working Group on Bribery reports from 1999 through early 2025 and found that virtually every major pharmaceutical company operating globally has been implicated in at least one foreign bribery scheme.¹

The underlying cases were drawn from U.S. Department of Justice and Securities and Exchange Commission enforcement actions documented over many years. Together, they reveal a pattern of corruption spanning dozens of countries and totaling more than one billion dollars in penalties.

Pfizer, GlaxoSmithKline, Sanofi Among Vaccine Companies Implicated

The researchers identified 21 investigations involving 19 pharmaceutical companies and numerous subsidiaries across five OECD member nations. The United States accounted for 14 of those investigations, followed by Germany and Denmark with three each, and Greece and Italy with one each.² Among the companies publicly named were Pfizer, Johnson & Johnson, Novartis, Teva, GlaxoSmithKline, AstraZeneca, Bristol-Myers Squibb, Sanofi, Eli Lilly, Novo Nordisk, SciClone, BioTest, and Nordion.³

The study defines bribery as “the offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal, unethical or a breach of trust.”⁴

The authors explain:

… pharmaceutical company bribes and other financial inducements can distort prescribing and compromise regulations that are designed to ensure drug safety and efficacy. More generally, pharmaceutical industry corruption affects patient safety and health care resource allocation worldwide.⁵

Over One Billion Dollars in Sanctions Paid Out by Companies

The implicated companies paid a combined $1,111,225,911 in sanctions. That total included $586,263,414 in fines, $447,237,274 in returned profits, and $77,545,872 in prejudgment interest.⁶ Despite the scale of the financial penalties, not one company admitted wrongdoing in any of the 21 cases.⁷

How the Bribery Schemes Operated

The study found that bribery schemes were not isolated acts by low-level employees acting on their own. Rather, senior executives and regional directors within the drug companies approved and, in some cases, directed the payments. Subsidiaries, shell companies, and third-party vendors were used to route payments and give them the appearance of legitimacy. Twelve of the 19 investigations found that subsidiaries were used specifically to conceal bribery operations. The bribes were used to secure regulatory approvals, influence prescribing patterns, and drive drug sales in markets around the world.⁸

Bribes Hidden in Distributor Discounts

A second pattern identified in the study involved pharmaceutical companies granting unusually steep discounts to distributors. The distributors then used the excess funds to pay bribes to physicians and government officials. Companies falsely recorded the discounts as legitimate marketing or sales expenses, concealing the payments in their books.

The arrangement had a direct consequence for patients. When physicians received payments tied to a particular drug, their prescribing decisions were driven by financial benefit rather than patient need.¹⁰

Novartis Vietnam worked with a distributor that paid bribes directly to healthcare providers and reimbursed up to 50 percent of those costs through credit notes. Teva Mexico funneled cash to physicians through a Copaxone distributor and mislabeled the payments as revenue reductions. Eli Lilly’s Brazilian subsidiary granted discounts of 17 to 19 percent instead of the standard 10 percent, concealing a six percent bribe to state officials within the markup.¹¹

Novartis

Between 2012 and 2015, a Novartis subsidiary in Greece bribed employees at state-owned hospitals and clinics to increase prescriptions for Lucentis, a drug used to treat macular degeneration. Physicians were paid more than $5,000 per event attended. Internal Novartis documents described the arrangement as a return on investment and tied physician payments to their prescription volumes.¹²

In South Korea, a Novartis subsidiary channeled more than $16.3 million through third-party medical journals as improper payments to physicians. In June 2020, Novartis and its subsidiaries agreed to pay $345 million to resolve Foreign Corrupt Practices Act charges brought by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). Novartis Hellas SACI paid a criminal penalty of $225 million and entered a three-year deferred prosecution agreement.¹³

Johnson & Johnson

In Greece, Poland, and Romania, Johnson & Johnson subsidiaries and agents used slush funds, sham contracts, and offshore accounts in the Isle of Man to reward physicians and hospital administrators. The drug company was also accused of paying kickbacks in Iraq.

Johnson & Johnson agreed to pay more than $48 million to resolve SEC charges and $21.4 million to resolve parallel DOJ criminal charges. However, the large pharmaceutical company did not admit or deny the allegations.¹⁴

Pfizer

Pfizer subsidiaries in Italy and Russia were accused by the SEC in 2012 of paying bribes over approximately a decade to foreign government officials. They paid the bribes in order to secure regulatory and formulary approvals, boost sales, and increase prescriptions.

After voluntarily disclosing the misconduct in 2004, Pfizer agreed to pay $26.3 million to the SEC to resolve the charges. Its subsidiary Pfizer HCP paid a separate $15 million criminal penalty to the DOJ. Like the other big pharmaceutical companies, Pfizer did not admit or deny the allegations.¹⁵

Teva

Teva Pharmaceuticals made illicit payments to government officials in Russia, Ukraine, and Mexico to increase market share, according to the U.S. Department of Justice and the SEC. Those payments generated $214 million in illegal profits. Teva agreed to pay $283 million in criminal fines to the DOJ and $236 million in disgorgement and prejudgment interest to the SEC, for a combined total of $519 million.¹⁶

GlaxoSmithKline

GlaxoSmithKline’s subsidiary in China was fined CN¥3 billion by Chinese authorities after an investigation found it had bribed physicians to increase drug sales. It was the largest fine imposed by a Chinese court at the time. The Securities and Exchange Commission later resolved Foreign Corrupt Practices Act charges against the company for the same conduct, settling for $20 million.¹⁷

AstraZeneca and Sanofi

AstraZeneca paid $5.5 million to the SEC to resolve charges that it made improper payments to government-controlled healthcare providers in China and Russia.¹⁸ Sanofi settled Foreign Corrupt Practices Act charges with the SEC for $25.2 million in 2018. The agency found that employees and agents in multiple countries made improper payments to foreign officials, including physicians, between 2011 and 2015.¹⁹

Zero Admissions of Wrongdoing

Across all 21 investigations spanning more than two decades of OECD monitoring, no pharmaceutical company admitted any wrongdoing. Companies paid the over one billion dollars in combined penalties and moved forward. The study’s authors concluded that bribery in the pharmaceutical sector is not an isolated event but a systemic and recurring feature of how some of the world’s largest drug companies have operated in markets across the globe.^20 21

The authors suggest that the wide-spread pattern of bribery across the pharmaceutical industry is indicative of institutional corruption. Both the legal and illegal acts of bribery by big pharma “pervert institution’s function under conditions that may promote personal benefit” and serve to undermine the public.

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