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Criminal Information Filed
Novartis Bribed Greek Doctors With Free Trips and Fake Studies to Sell More Drugs
Between 2008 and 2015, Novartis Hellas ran two parallel bribery schemes targeting Greek public health officials, paying them thousands to prescribe its drugs while hiding the payments as business expenses in reports to U.S. regulators.
🔴 CRITICAL SEVERITY
TL;DR
Novartis Hellas, the Greek subsidiary of pharmaceutical giant Novartis AG, ran a systematic bribery operation targeting Greek government doctors from at least 2008 through 2015. The company paid public health officials to prescribe its drugs by sponsoring all-expenses-paid trips to international medical conferences, and by enrolling them in a fake “epidemiological study” that paid them directly for each prescription they wrote. Both schemes were concealed in Novartis AG’s books as legitimate advertising expenses, which were then used to falsify financial reports filed with the U.S. Securities and Exchange Commission. This is not a regulatory gray area. Novartis Hellas bribed public officials, corrupted medical judgment, and lied to U.S. regulators. Patients and the Greek public health system paid the price so Novartis could extract at least $71.48 million in ill-gotten profits.
This conduct is unacceptable. Demand that pharmaceutical companies face consequences that match the scale of harm they cause.
📊 Key Numbers
$71.48M
Profits from bribery schemes (Sentencing Guidelines calculation)
$3.8M
Payments to doctors through the EXACTLY study alone
2,200+
Doctors enrolled in the fraudulent EXACTLY study
44,000+
Patients enrolled in EXACTLY, without their informed consent to a marketing scheme
$6,000+
Typical per-doctor cost of a bribe trip to an international conference
$89,000
Cost to send 10 doctors to a single U.S. ophthalmology congress in New Orleans
7 Years
Duration of the criminal conduct (2008–2015)
2 Counts
Criminal charges filed by DOJ: FCPA bribery conspiracy and books-and-records conspiracy
⚠️ Breakdown of Misconduct
Core Allegations
What Novartis Hellas Actually Did · 7 Points
▾
| 01 | Novartis Hellas paid Greek government doctors to attend international medical conferences in the United States and Europe as a deliberate strategy to increase prescriptions of its eye drug Lucentis. The payments included airfare, hotel accommodations, and conference registration fees often exceeding $6,000 per doctor. | high |
| 02 | Novartis Hellas created a fake “epidemiological study” called EXACTLY that paid over 2,200 doctors directly, targeting over 44,000 patients. Novartis employees and managers acknowledged internally that doctors understood they were being paid to prescribe drugs, not to conduct research. | high |
| 03 | Novartis Hellas created internal “Action Plan KOLs” documents that explicitly tracked which doctors to target, what benefits to give them, and how to “increase loyalty” and “change mindset about cooperation.” These were written plans to purchase medical judgment. | high |
| 04 | Novartis Hellas internally classified doctors by their “propensity to prescribe Lucentis” and only gave congress trip “investments” to high-value prescribers. Doctors who wrote fewer Lucentis prescriptions received no such benefits, making the transactional nature of the scheme explicit. | high |
| 05 | All bribe payments were falsely recorded in Novartis Hellas’s internal accounting as legitimate “advertising and promotion expenses.” These fraudulent records flowed directly into Novartis AG’s global financial statements, which were filed with the U.S. Securities and Exchange Commission. | high |
| 06 | Novartis Hellas employees traveled to the United States and, while on U.S. soil, facilitated the attendance of Greek government doctors at American ophthalmology congresses as part of the bribery scheme, bringing the criminal conduct squarely within U.S. jurisdiction. | high |
| 07 | Novartis Hellas internally documented threats to withdraw congress sponsorships as punishment for doctors who did not improve their Lucentis sales performance, treating government health officials as salespeople on a corporate quota system. | high |
Profit Over People
Revenue Prioritized Over Medical Ethics · 5 Points
▾
| 01 | The EXACTLY “study” had a planned ROI of 3.04, meaning Novartis Hellas expected every $1 invested in doctor bribes to return $3.04 in drug sales. The company treated patient care as a financial instrument. | high |
| 02 | The total planned payout to doctors through EXACTLY was over 2.8 million euros (approximately $3.8 million), with an expected return of over 8.6 million euros ($11.9 million) in drug sales. Novartis Hellas calculated the return on corrupting doctors the way a trader calculates arbitrage. | high |
| 03 | Novartis Hellas recognized at least $71.48 million in profits from both schemes, a figure calculated under U.S. Sentencing Guidelines, representing profits extracted through the systematic corruption of public health officials who were supposed to serve patients. | high |
| 04 | A Novartis Hellas medical manager internally acknowledged that the fake clinical study was “a part of the marketing mix,” confirming that the company understood it was buying prescriptions rather than conducting science. | high |
| 05 | Novartis Hellas’s brand team created a basketball-themed presentation in 2014 that described strategies for “converting” doctors who preferred cheaper competitor drugs. The playbook for overcoming those “defenses” was the systematic application of financial inducements to public health officials. | med |
Public Health and Safety
Corrupted Medical Judgment, Harmed Patients · 4 Points
▾
| 01 | Doctors enrolled in the EXACTLY scheme were being paid to prescribe Novartis hypertension drugs to patients, including over 16,000 newly diagnosed or uncontrolled patients. Medical decisions for these patients were shaped not by clinical evidence but by Novartis’s financial incentives. | high |
| 02 | Many of the case report forms submitted under EXACTLY contained mistakes and inconsistencies, including failing to document whether patients suffered from coronary disease, a condition strongly linked to hypertension and directly relevant to prescribing decisions. The “study” was scientifically worthless because it was never meant to be science. | high |
| 03 | Lucentis, the drug at the center of the congress bribery scheme, was prescribed for neovascular age-related macular degeneration, a serious, vision-threatening condition. Doctors treating patients with this condition were having their prescribing decisions corrupted by Novartis travel payments. | high |
| 04 | The bribed doctors worked at Greek state-owned hospitals and clinics, meaning the patients most harmed by corrupted prescribing were those relying on the Greek public health system: patients who had no choice but to trust the judgment of doctors whose judgment Novartis had already purchased. | high |
Regulatory Failures and Accounting Fraud
How Novartis Hid Its Crimes from U.S. Regulators · 4 Points
▾
| 01 | Bribe payments for the congress scheme were recorded in Novartis Hellas’s books as “advertising and promotion expenses,” completely concealing their corrupt nature and bypassing FCPA compliance controls. | high |
| 02 | Bribe payments under the EXACTLY scheme were also falsely recorded as advertising and promotion expenses, meaning both schemes used identical accounting fraud to disguise criminal conduct as ordinary business costs. | high |
| 03 | These false records were consolidated into Novartis AG’s global financial statements, which the parent company filed with the U.S. Securities and Exchange Commission. The fraud in Greece corrupted official financial disclosures submitted to U.S. investors and regulators. | high |
| 04 | Novartis Hellas’s own Country Compliance Board reviewed the EXACTLY project and deemed it “of high value,” approving it for internal use despite the clear marketing purpose that should have triggered compliance rejection. Internal gatekeepers approved the scheme. | med |
Corporate Accountability Failures
No Executives Named, Systemic Impunity · 4 Points
▾
| 01 | The DOJ charged Novartis Hellas as a corporate entity. The employees who wrote and executed the Action Plans, ran the EXACTLY scheme, and falsified accounting records are referred to only as “Employee 1” and “Employee 2” in the charging document. No executives at Novartis AG are named. | high |
| 02 | The criminal information was filed in June 2020, covering conduct that began in 2008. The schemes ran for at least seven years before federal charges were filed, suggesting enforcement lag that benefits corporate defendants. | high |
| 03 | The same conduct was documented internally by Novartis Hellas and approved by its own Country Compliance Board, yet the company continued operating without internal intervention for years. Internal compliance mechanisms failed entirely. | med |
| 04 | Novartis Hellas’s parent company, Novartis AG, traded on the New York Stock Exchange under the symbol NVS throughout this period. American investors held shares in a company whose subsidiary was running criminal bribery operations disclosed to the SEC as advertising costs. | med |
The Language of Legitimacy
How Novartis Called Bribery “Science” · 4 Points
▾
| 01 | Novartis Hellas’s written policies stated that sending doctors to international congresses was for “scientific or educational information.” Its internal documents simultaneously and explicitly described those trips as tools to “increase pressure” on doctors and coerce higher prescription volumes. | high |
| 02 | The EXACTLY bribery scheme was redesigned and renamed an “epidemiological investigational study” after Novartis Hellas’s compliance board flagged that it would need government approval. The company repackaged a marketing operation as medical research to obtain regulatory approval for paying doctors. | high |
| 03 | Payments to doctors under the bribery schemes were called “investments” in internal Novartis Hellas documents. The word “bribe” appears nowhere in their documentation because corporate euphemism served as both legal cover and cultural normalization for criminal conduct. | med |
| 04 | Novartis Hellas’s Lucentis Brand Team held a meeting in September 2012 with a written agenda section explicitly titled “Increase Pressure in HCPs,” yet framed the congress sponsorships as educational support. The gap between external framing and internal documentation reveals calculated deception. | med |
🕐 Timeline of Events
Nov 2008
Novartis Hellas brand managers develop the “EXACTLY” marketing project targeting over 2,200 doctors and 44,000 patients with planned $3.8M in payments to physicians. The project summary is submitted to the internal Country Compliance Board, which approves it and deems it “of high value.”
Feb 2009
The Greek National Organization for Medicines approves EXACTLY as an “investigational study” after Novartis Hellas redesigns it to appear scientific. The approval gives the scheme governmental legitimacy it does not deserve.
Apr–Dec 2009
Novartis Hellas and enrolled doctors conduct the EXACTLY study. Payments flow to doctors. Many submitted case report forms contain errors and omissions that would be disqualifying in any legitimate scientific study.
Apr 2010
Novartis Hellas holds an internal “EXACTLY Debrief” meeting, audio-recorded. Multiple managers and employees openly acknowledge that doctors understood they were being paid to prescribe drugs, not conduct research. No corrective action is taken.
Sep 2012
Novartis Hellas’s Lucentis Brand Team holds a documented meeting. Written minutes include a section titled “Increase Pressure in HCPs” that explicitly describes using congress sponsorships to coerce Greek government doctors into writing more Lucentis prescriptions.
2012–2015
Novartis Hellas pays for Greek government ophthalmologists to attend international congresses in the United States and Europe, with costs per doctor often exceeding $6,000. Novartis employees travel to the United States to facilitate these sponsorships on U.S. soil.
Jan 2013
Novartis Hellas Employee 1 prepares “Action Plan KOLs,” a detailed document targeting specific Greek government doctors, setting goals to capture 100% of their Lucentis-eligible prescriptions and outlining congress trips as the mechanism to coerce compliance.
Late 2013
Novartis Hellas employees travel to the United States and facilitate attendance of Greek government doctors at the U.S. Academy ophthalmology congress in New Orleans. The company spends the equivalent of $89,000 to send 10 doctors to that single event.
2014
Novartis Hellas managers produce a basketball-themed presentation for the Lucentis brand team describing strategies to “convert” doctors away from competitor drugs using improper financial inducements.
Jun 25, 2020
The U.S. Department of Justice files a two-count criminal information against Novartis Hellas S.A.C.I. in the District of New Jersey. Charges include conspiracy to violate the FCPA’s antibribery provisions and conspiracy to falsify books and records filed with the SEC. The conduct had been ongoing for at least 12 years before charges were filed.
💬 Direct Quotes from the Legal Record
QUOTE 1
Internal threat to doctors who didn’t prescribe enough Lucentis
Core Allegations
“must understand that their participation in [specific congresses in the United States and Europe] will be cancelled if sales performance is not improved significantly.”
💡 This is the company’s written internal minutes, instructing staff to threaten Greek government doctors that their free trips would be revoked if they didn’t write more prescriptions. This is not ambiguous. It is documented coercion of public health officials.
QUOTE 2
Withdrawal of benefits as “serious consequences”
Core Allegations
“REPs must make clear to their [HCP] customers that Lucentis is facing real difficulties in the market and for this reason there will be serious consequences.”
💡 Sales representatives were directed to tell government doctors that failing to increase prescriptions would bring “serious consequences,” using the language of threat to coerce public officials. This is documented in the company’s own meeting minutes.
QUOTE 3
The target: 100% of a doctor’s prescriptions
Core Allegations
“ASK HIM ALL,” meaning that the goal was to capture 100% of Greek HCP 1’s ophthalmology prescriptions for which Lucentis could be prescribed.
💡 The Action Plan did not aim to inform. It aimed to monopolize a doctor’s prescription pad entirely for Novartis drugs, using international conference sponsorships as leverage. This is the extraction of a public official’s medical judgment for corporate profit.
QUOTE 4
Novartis manager acknowledges doctors knew they were being paid to prescribe
Public Health and Safety
“[A]lthough the microphone is recording . . . you all know this very well, I just repeat, that the doctor believes that he/she participates in a study [EXACTLY] and gets paid for what he prescribes in reality and not for what he/she writes in the study. . . Consequently, the doctor’s impression was that they participate just so that they get paid for what they prescribe.”
💡 A Novartis Hellas manager admitted in an audio-recorded internal meeting that the company knew doctors believed they were being paid to prescribe drugs, not conduct research. The manager acknowledged this while noting the microphone was on. Novartis took no corrective action.
QUOTE 5
Sales manager confirms EXACTLY was a prescription-buying scheme
Public Health and Safety
“[T]he main issue is . . . that the doctors believe that the study was conducted in order to get paid for what they write, right?”
💡 A Novartis Hellas sales manager openly acknowledged in an internal meeting that EXACTLY was understood by participating doctors as a scheme to pay them for prescriptions. No one in that meeting reported the conduct to regulators or stopped it.
QUOTE 6
Medical manager calls bribery part of the “marketing mix”
Profit Over People
“a clinical study ‘is a part of the marketing mix; we do not disagree that this is a type of benefit provided to the doctors. They know that they will get paid, this is what happens in reality.'”
💡 A Novartis Hellas medical manager stated outright that the fake clinical study was a marketing tool, that it was a benefit paid to doctors, and that everyone knew it. This was not a compliance failure. This was deliberate corporate policy.
QUOTE 7
Brand manager admits studies were “marketing projects”
Language of Legitimacy
“To be honest, the studies were conducted in a similar way in the past as well; they were conducted as marketing projects. That’s within quotation marks. Between us.”
💡 A Novartis Hellas brand manager admitted that using fake studies to market drugs was an established practice, not a one-off. The phrase “between us” confirms the company understood this conduct was illegal and actively concealed it.
QUOTE 8
The message Novartis told reps to deliver to bribed doctors
Core Allegations
“to get you must write. No presents anymore.”
💡 The Action Plan for a specific Greek government doctor instructed Novartis Hellas employees to tell the doctor that congress trip benefits were now conditional on writing prescriptions. This is the company’s own documented text making the transaction explicit: prescriptions in exchange for gifts.
QUOTE 9
Penalty for not prescribing enough: reduced investment
Core Allegations
“[l]ower investment [in another Greek State HCP] as a penalty for [Lucentis injection] loss” while making their “motive (large investment)” visible to the HCP.
💡 Novartis Hellas documented that reducing a doctor’s “investment” (travel perks) was used as a formal penalty for failing to prescribe enough Lucentis. Government doctors were being managed on a corporate incentive structure, with bribes as bonuses and benefit cuts as discipline.
QUOTE 10
The EXACTLY study’s ROI calculation reveals its true purpose
Profit Over People
With an anticipated return on investment (“ROI”) of 3.04, the planned investment of over 2.8 million euros . . . in payments to HCPs through EXACTLY was expected to yield sales of over 8.6 million euros.
💡 The Project Summary for EXACTLY included a projected financial return on the doctor payments. No legitimate scientific study calculates an ROI on researcher compensation. This document proves EXACTLY was a drug sales operation dressed in the language of medical research.
💬 Commentary
❓
What exactly did Novartis Hellas do wrong?
▾
Novartis Hellas ran two criminal schemes simultaneously. In the first, between 2012 and 2015, it paid Greek government doctors thousands of dollars in travel expenses to attend international medical conferences as a reward for prescribing its eye drug Lucentis, and threatened to cut off those benefits if prescriptions fell short. In the second, between 2008 and 2009, it created a fraudulent “epidemiological study” called EXACTLY, which paid over 2,200 doctors directly as a pretext for purchasing their prescriptions for Novartis hypertension drugs. Both schemes violated the Foreign Corrupt Practices Act, which prohibits bribing foreign government officials. Both schemes were concealed through false accounting entries that flowed into Novartis AG’s SEC filings. This is not regulatory gray zone. It is documented criminal conduct over a seven-year period, acknowledged in the company’s own audio-recorded internal meetings.
❓
Were these doctors considered government officials? Why does that matter?
▾
Yes. Greece’s hospitals and clinics were state-owned and state-controlled, making their employees “foreign officials” under the FCPA. That classification is critical because it means Novartis Hellas was not simply giving gifts to private doctors; it was bribing public servants who had a legal duty to prescribe drugs based on patient need and medical evidence. When a pharmaceutical company corrupts a government doctor, it does not just harm the individual patient in front of that doctor. It undermines the entire public health system, which is supposed to allocate care based on clinical need, not on which company spent the most on international travel.
❓
How were patients harmed?
▾
Patients were harmed in concrete, direct ways. Doctors enrolled in EXACTLY were being paid to prescribe Novartis drugs regardless of whether those drugs were the best choice for their patients. Over 44,000 patients, including more than 16,000 newly diagnosed or uncontrolled hypertension patients, were enrolled in a study that was not designed to answer clinical questions. It was designed to enrich Novartis. Patients with serious eye conditions such as macular degeneration had their doctors’ prescribing decisions shaped not by medical evidence but by Novartis congress trips. And because the bribed doctors worked in state hospitals, the patients most exposed were those who depended on Greece’s public health system, the people who had the least ability to seek alternative care.
❓
Is this a serious case, or just a technical legal violation?
▾
This is serious. The DOJ filed criminal charges, not a civil fine. The conduct spanned at least seven years, involved multiple coordinated schemes, was documented in written internal plans and audio-recorded meetings, and generated at least $71.48 million in calculated criminal profits. Novartis Hellas did not stumble into a gray area. Its own employees acknowledged on tape that they knew the EXACTLY payments were bribes, not research fees. Its own internal documents framed congress trips as coercive tools with explicit threats attached. The company’s compliance board approved the scheme. This is systemic, willful, documented corporate criminality, not a paperwork error.
❓
Why wasn’t anyone personally prosecuted?
▾
The DOJ charged Novartis Hellas as a corporation. The individuals who wrote the Action Plans, ran the EXACTLY scheme, approved payments, and falsified the accounting records are referenced only as “Employee 1” and “Employee 2.” No Novartis AG executives are named. This reflects a broader pattern in U.S. corporate enforcement: companies pay fines while the individuals who make decisions often face no personal consequences. When corporations bear all the risk and individuals bear none, the financial calculation for future misconduct does not change enough to deter it. Corporate accountability that stops at the corporate level is not accountability; it is a cost of doing business.
❓
How did Novartis hide this from regulators?
▾
Novartis Hellas used two layers of concealment. First, it labeled bribe payments as “advertising and promotion expenses” in its internal accounting, disguising criminal payments as routine business costs. Second, those falsified records were consolidated into Novartis AG’s global financial statements, which were filed with the U.S. Securities and Exchange Commission. That means U.S. investors and regulators reviewing Novartis AG’s official filings saw fraudulent numbers. The company also dressed up the EXACTLY bribery scheme as a government-approved scientific study, obtaining regulatory approval by recasting a marketing operation as research. The sophistication of the concealment underscores that this was deliberate, not accidental.
❓
Is Novartis Hellas an isolated case or part of a pattern?
▾
Novartis Hellas is not isolated. The pharmaceutical industry has faced repeated FCPA enforcement actions for paying doctors in multiple countries to prescribe specific drugs. Novartis AG itself, the parent company, has faced multiple enforcement actions globally. What the Novartis Hellas case illustrates is a structural problem: when pharmaceutical companies’ revenues depend on individual prescribing decisions, and when the consequences of bribery are treated as a manageable legal risk rather than an existential penalty, the incentive to corrupt medical judgment persists. Changing this requires stronger individual accountability, penalties calibrated to harm rather than to profits, and structural reforms to how pharmaceutical companies are permitted to interact with prescribers.
❓
What can I do to prevent this from happening again?
▾
Several actions matter. Support organizations that advocate for stronger pharmaceutical transparency laws and individual corporate accountability in criminal enforcement. Contact your elected representatives and demand that FCPA enforcement include personal criminal charges for executives who approve bribery schemes, not just corporate fines. If you work in healthcare, familiarize yourself with your legal obligations under anti-kickback statutes and report suspected pharmaceutical inducements to your institution’s compliance office or to the HHS Office of Inspector General. If you are a patient, ask your doctor about the clinical evidence behind any prescription and check the Open Payments database (openpaymentsdata.cms.gov) to see if your doctor has received payments from pharmaceutical companies. Transparency, individual accountability, and informed patients are the most powerful checks on this type of corporate misconduct.
You can visit this link for a press release on the DOJ’s website about this settlement: https://www.justice.gov/usao-nj/pr/novartis-ag-and-subsidiaries-pay-345-million-resolve-foreign-corrupt-practices-act-cases
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