On August 7, 2012, the SEC filed a complaint against Pfizer Inc. ("Pfizer") alleging violations of the Foreign Corrupt Practices Act relating to improper payments made to foreign officials in numerous countries by the employees and agents of Pfizer's subsidiaries in order to assist Pfizer in obtaining or retaining business. At various times from at least 2001 through 2007, employees and agents of Pfizer's subsidiaries, conducting business in Bulgaria, China, Croatia, Czech Republic, Italy, Kazakhstan, Russia, and Serbia, engaged in transactions for the purpose of improperly influencing foreign officials, including doctors and other healthcare professionals employed by foreign governments. Employees attempted to conceal the true nature of the transactions by improperly recording the transactions on the books and records of the respective subsidiaries. These improper payments were made without the knowledge or approval of officers or employees of Pfizer, but the inaccurate books and records of Pfizer's subsidiaries were consolidated in the financial reports of Pfizer.

On August 7, 2012, the SEC charged Pfizer Inc. with violating the Foreign Corrupt Practices Act when its subsidiaries in Europe and Asia bribed doctors and other health care professionals to win business.

On August 8, 2012, the SEC published a litigation release regarding this matter. According to the release: "The SEC alleges that employees and agents of Pfizer's subsidiaries in Bulgaria, China, Croatia, Czech Republic, Italy, Kazakhstan, Russia, and Serbia made improper payments to foreign officials to obtain regulatory and formulary approvals, sales, and increased prescriptions for the company's pharmaceutical products. They tried to conceal the bribery by improperly recording the transactions in accounting records as legitimate expenses for promotional activities, marketing, training, travel and entertainment, clinical trials, freight, conferences, and advertising."

On August 27, 2012, Federal District Judge Ellen S. Huvelle entered final judgment against Pfizer Inc. pursuant to the consent of Pfizer Inc. The Order provided that "based on Pfizer's exemplary cooperation in a Commission investigation, the Court is not ordering Pfizer to pay a civil penalty."