July 6, 2020, ACT agreed: A $3.5 million fine to settle the FTC`s allegations that it breached the terms of the approval decision it received in 2018 following the acquisition of some 2018 Holiday.1 The Commission stated that ACT had not made the necessary divestitures in the approval decision on time and had not maintained the viability of a divested site or submitted sufficiently detailed compliance reports. In a statement of 50, the FTC stated that “the colony is sending a strong message to the public that the Commission takes its orders seriously and the parties should do so.” 2 The Skadden Situation and Settlement Agreement provides the regulated community with an important insight into FARA compliance, including: “According to the transaction agreement, [Skadden] would have required, among other things, accurate and complete information on the compensation it received for the preparation of the report on behalf of the [Ukrainian government] and the identity of the entity that paid to do so. The transaction agreement also states that “Skadden has already taken important steps to meet its conditions and, as long as the company continues to comply with them, the department will not take any action against the company in relation to its conduct in this matter.” As part of the agreement, the law firm agreed to retroactively register as a foreign agent for Ukraine and pay $4.6 million to the government, representing the money it earned working in Ukraine. While salespeople have long been an integral part of the companies` sales and marketing efforts, the DOJ challenges the participation of Novartis sales agents in the spokesperson selection process. The settlement agreement includes that Novartis agents require sales agents to provide data – which allowed them to identify large numbers of prescribing agents who could be appointed as spokespersons – and a wide margin of appreciation for Novartis sales representatives and directors to determine which local physicians should be appointed as spokespersons. Although high-prescription physicians generally have the experience to speak intelligently about a product on behalf of a company, it is likely that the DOJ`s concerns are due to the fact that prescription physicians may have been chosen as paid referents, particularly because they were high prescription. To curb these practices, the CIA requires that stakeholders be selected on the basis of objective and standardized criteria, without the participation of foreign service personnel, a practice that many companies have already adopted. 2 Novartis recently entered into a separate transaction with the United States.