Today the UK SFO obtained a Civil Recovery Order against DePuy International Limited. The company is ordered to pay £4.829 million, plus costs, in recognition of unlawful conduct relating to the sale of orthopaedic products in Greece between 1998 and 2006.

In parallel the DOJ obtained a $21.4 million penalty to resolve criminal FCPA charges with $48.6 million going to the SEC in disgorgement and prejudgment interest to settle the SEC’s civil charges.

The case highlights the UK SFO’s increasing use of Proceeds of Crime legislation to achieve its purposes.