The SEC stated: "From approximately 2000 through 2003, Novo Nordisk A/S ("Novo Nordisk" or the "Company") violated the books and records and internal controls provisions of the Foreign Corrupt Practices Act (the "FCPA") by paying $1,437,946 in kickbacks and agreeing to pay an additional $1,315,454 in kickbacks in connection with its sale of humanitarian goods to Iraq under the United Nations Oil for Food Program (the "Program")."

On May 11, 2009, the Court issued a final judgment as to Defendant Novo Nordisk A/S stating: "Defendant Novo Nordisk A/S . . . consented to entry of this Final Judgment without admitting or denying the allegations of the Complaint (except as to jurisdiction); waived findings of facts and conclusions of law; and waived any right to appeal from this Final Judgment."

The SEC stated that: "[It] filed Foreign Corrupt Practices Act books and records and internal controls charges against Novo Nordisk in the U.S. District Court for the District of Columbia. . . . The Commission's complaint alleges that from 2000 through 2003, Novo Nordisk paid $1,437,946 in kickbacks and agreed to pay an additional $1,315,454 in kickbacks in connection with its sale of humanitarian goods to Iraq under the United Nations Oil for Food Program."