On December 20, 2012, the SEC charged Eli Lilly with violations of the Foreign Corrupt Practices Act "in connection with the activities of its subsidiaries in China, Brazil, Poland and Russia."

On December 20, 2012, the SEC announced that it charged Eli Lilly and Company ("Lilly") with violations of the Foreign Corrupt Practices Act ("FCPA") for improper payments its subsidiaries made to foreign government officials to win millions of dollars of business in Russia, Brazil, China, and Poland. According to the SEC's complaint filed in federal court in Washington D.C., the Indianapolis-based pharmaceutical company's subsidiary in Russia used offshore "marketing agreements" to pay millions of dollars to third parties chosen by government customers or distributors, despite knowing little or nothing about the third parties beyond their offshore address and bank account information. Moreover, when the company became aware of possible FCPA violations in Russia, Lilly did not curtail the subsidiary's use of the marketing agreements for more than five years. Further, Lilly subsidiaries in Brazil, China, and Poland also made improper payments to government officials or third-party entities associated with government officials. Without admitting or denying the allegations, Lilly agreed to pay more than $29 million to settle the SEC's charges. In addition, Lilly consented to the entry of a final judgment permanently enjoining the company from violating the anti-bribery, books and records, and internal controls provisions of the FCPA and agreed to comply with certain undertakings including the retention of an independent consultant to review and make recommendations about its foreign corruption policies and procedures. The settlement is subject to court approval.

On January 2, 2013, Federal District Judge Beryl A. Howell entered final judgment against Eli Lilly and Company pursuant to the consent of Eli Lilly and Company.