According to The FCPA Blog the sales practices of large pharmaceutical companies have for a long time involved (and may still involve) payments of some sort to doctors, in exchange for recommendations for their products or actual sales. Because doctors overseas who work in government owned or managed hospitals are considered to be 'foreign officials' under the Foreign Corrupt Practices Act, those payments may create offenses under U.S. law. The relevant elements of an FCPA offense are (1) giving or promising to give (2) anything of value (3) to a foreign official (4) with a corrupt intent (5) to obtain or retain business. The overseas sales practices of big pharmas seem to satisfy every element of an FCPA offense, so the DOJ and SEC are taking a close look and will likely bring some enforcement actions at some point.