Stryker Corporation (Stryker), a Michigan-based medical technology company, has settled an FCPA matter with the Securities and Exchange Commission (SEC), in which the SEC alleged that Stryker made $2.2 million in unlawful cash payments, gifts, hospitality, and charitable donations for the benefit of foreign government officials while describing the payments as legitimate expenses in the company’s books and records. Stryker’s subsidiaries in Mexico, Poland, Romania, Argentina, and Greece allegedly were involved in the conduct, and the SEC faulted Stryker for not adequately implementing its corporate anti-corruption policies at its foreign subsidiaries. The gifts and hospitality that the SEC found problematic included paying for officials’ vacations and, in at least one instance, paying lodging for a foreign official to attend a conference abroad where the officials were viewed as key to Stryker obtaining business. The SEC also found a charitable donation to fund a public university research lab to be corrupt, where the lab was the ‘pet project’ of a research physician viewed as key to obtaining business from the university. Stryker settled with the SEC for a total of $13M, comprised of $7.5M in disgorgement, plus a civil penalty and pre-judgment interest. See Order Instituting Cease-and-Desist Proceedings in re Stryker Corp., Exchange Act Release No. 70,751 (Oct. 24, 2013).