On April 8, 2011, the SEC filed a complaint in the District Court for the District of D.C. alleging that Johnson & Johnson subsidiaries, employees, and agents paid bribes to doctors in Greece, Poland, and Romania. In addition, "J&J's subsidiaries and agent paid kickbacks to Iraq in order to obtain contracts under the United Nations Food for Oil Program." The SEC alleges that J&J violated the Exchange Act by making illicit payments to foreign officials and by failing to record these payments properly or have adequate internal controls in place.

On April 7, 2011, the SEC announced that it charged Johnson and Johnson ("J&J") with violating the Foreign Corrupt Practices Act ("FCPA") by bribing public doctors in several European countries and paying kickbacks to Iraq to illegally obtain business. Without admitting or denying the SEC's allegations, J&J has consented to the entry of a court order permanently enjoining it from future violations of future securities laws, to pay $38,227,826 in disgorgement and $10,438,490 in prejudgment interest, and to comply with certain undertakings regarding its FCPA compliance program. J&J voluntarily disclosed some of the violations by its employees and conducted a thorough internal investigation to determine the scope of the bribery and other violations, including proactive investigations in more than a dozen countries by both its internal auditors and outside counsel. J&J's internal investigation and its ongoing compliance programs were essential in gathering facts regarding the full extent of J&J's FCPA violations. In a related criminal proceeding, J&J agreed to pay an additional $21.4 million fine to settle the charged brought by the U.S. Department of Justice, and a resolution of a related investigation by the United Kingdom Serious Fraud Office is anticipated.

On April 13, 2011, Federal District Judge Gladys Kessler entered final judgment against Johnson & Johnson pursuant to the consent of Johnson & Johnson.