On February 6, 2012, the SEC filed a complaint against Smith & Nephew PLC, a medical device company with its headquarters in London, England, in a case involving bribery of public doctors. The SEC alleged that "from 1997 to June 2008, two of Smith & Nephew PLC's subsidiaries "used a distributor to create a slush fund to make illicit payments to public doctors employed by government hospitals or agencies in Greece." Payments were made under the guise of marketing services, despite no such service being rendered. Additionally, the SEC alleged that Smith & Nephew failed to maintain its books and record and failed to maintain adequate internal controls.

On February 6, 2012, the SEC announced a settlement with Smith & Nephew PLC to resolve "SEC charges that the global medical device company violated the Foreign Corrupt Practices Act (FCPA) when its subsidiaries bribed public doctors in Greece for more than a decade."

On February 6, 2012, the SEC announced that it charged London-based medical device company Smith & Nephew PLC with violating the Foreign Corrupt Practices Act ("FCPA") when its U.S. and German subsidiaries bribed public doctors in Greece for more than a decade to win business. According to the SEC's complaint filed in federal court in Washington, Smith & Nephew PLC's subsidiaries used a distributor to create a slush fund to make illicit payments to public doctors employed by government hospitals or agencies in Greece. On paper, it appeared as though Smith & Nephew PLC's subsidiaries were paying for marketing services, but no services were actually performed. Without admitting or denying the SEC's charges, Smith & Nephew PLC agreed to pay more than $5.4 million in disgorgement and prejudgment interest, consented to the entry of a court order permanently enjoining it from future violations of Sections 30A, 13(b)(2)(A), and 13(b)(2)(B) of the Securities Exchange Act of 1934 and ordering it to retain an independent compliance monitor for a period of 18 months to review its FCPA compliance program. Additionally, its subsidiary Smith & Nephew Inc. agreed to pay a $16.8 million fine as part of a deferred prosecution agreement with the Department of Justice.

On March 3, 2012, Federal District Judge Gladys Kessler entered final judgment against Smith & Nephew plc pursuant to the consent of Smith & Nephew plc.