On August 7, 2012, the SEC filed a complaint against Wyeth LLC. According to the complaint: "This action arises from violations of the books and records and internal controls provisions of the Foreign Corrupt Practices Act of 1977 ('the FCPA') by Defendant Wyeth LLC ('Wyeth'), while an issuer, relating to improper payments made to foreign officials in numerous countries by the employees and agents of Wyeth's subsidiaries in order to assist Wyeth in obtaining or retaining business. . . . At various times from at least 2005 through 2010, subsidiaries of Defendant Wyeth conducting business in several countries, including Indonesia, Pakistan, China, and Saudi Arabia, engaged in transactions for the purpose of improperly influencing foreign officials, including doctors and other healthcare professionals employed by foreign governments."

On August 8, 2012, the SEC published a litigation release regarding this matter. According to the release: "Wyeth subsidiaries engaged in FCPA violations, primarily before, but also after, the company's acquisition by Pfizer in late 2009. For example, according to the SEC's complaint, starting at least in 2005, subsidiaries marketing Wyeth nutritional products in China, Indonesia, and Pakistan bribed government doctors to recommend their products to patients by making cash payments or in some cases providing BlackBerrys and cell phones or travel incentives. The complaint alleges that Wyeth's employees often used fictitious invoices to conceal the true nature of the payments." The SEC also announced that the company had consented to an entry of a final judgment against it in settlement of the SEC's charges.

On August 29, 2012, Federal District Judge Amy Berman Jackson entered final judgment against Wyeth LLC pursuant to the consent of Wyeth LLC. The Order stated that "based on Wyeth's exemplary cooperation in a Commission investigation, the Court is not ordering Wyeth to pay a civil penalty."