Bondi made changes to DOJ policy. Her former client Pfizer might have benefited
But that appears to have changed after the Trump administration tapped Pam Bondi — previously an outside legal counsel for Pfizer — to lead the Justice department as attorney general.
In the company's most recent annual report, filed three weeks after Bondi took office in early February, there was no longer any reference to the Justice Department investigations into the company's potential violation of the Foreign Corrupt Practice Act. A quarterly report in May also contains no reference to these investigations.
On her first day in office, Bondi rolled back the enforcement of foreign corruption cases that didn't involve drug cartels and international criminal organizations, among a host of sweeping changes she made to the department's priorities. That move was followed five days later, on Feb. 10, by a related executive order issued by President Donald Trump that paused new foreign corruption investigations and enforcement actions.
The Justice Department also reportedly reduced the number of attorneys working on such cases and closed nearly half of existing foreign corruption cases.
Bondi's stated goal in making the changes was 'Removing Bureaucratic Impediments to Aggressive Prosecutions,' but the actions she and President Trump took were widely seen as a signal that the Justice Department would be less interested in pursuing allegations that major corporations like Pfizer paid bribes to win business abroad.
Pfizer is among several companies that filed financial documents this year suggesting that the Justice Department had dropped their federal corruption investigations.
The consumer advocacy group Public Citizen raised concerns about Bondi's relationship with Pfizer in a letter sent last month to the Senate Judiciary Committee and questions how she may have played a role in the department's apparent decision to drop the case.
'We would always hope that our elected officials are above reproach ethically and a big part of that is ensuring that they don't have any conflicts of interest,' said Lisa Gilbert, the group's co-president.
'All of this comes back to the appropriateness of Pam Bondi's conduct and whether she should be touching anything that approaches Pfizer.'
The Justice Department told The Miami Herald that Bondi's work for Pfizer had nothing to do with foreign corruption.
'Attorney General Bondi's brief work with this company occurred when she was a private citizen, concerned a Florida-specific legal matter, and bears no nexus whatsoever to the Department of Justice's FCPA guidance. Any suggestion to the contrary is incorrect,' said Justice Department spokesman Gates McGavick.
Pfizer declined to comment beyond the disclosures in the company's financial filings.
Work for Fort Lauderdale firm
Bondi – who previously served as Florida's attorney general for two terms and also was one of Trump's attorneys during his 2019 impeachment trial – represented Pfizer while in private practice with the Fort Lauderdale law firm Panza Maurer, which she had been affiliated with since 2021, according to her financial disclosure form.
It isn't clear exactly what Bondi did for Pfizer but the drug company is the only client she listed in connection with work for the law firm, which paid her more than $200,000 last year. Bondi also reported working as a lobbyist for the influential company Ballard Partners before entering office. The founder of that firm, Brian Ballard, also is listed as being of counsel with Panza Maurer, the same title Bondi held.
Thomas Panza, a founding partner of the law firm, declined to say whether the firm is still representing Pfizer and on what matters it has represented the pharmaceutical company. He said Bondi did work for other clients besides Pfizer in the past, but declined to provide names.
He also said that, to his knowledge, no one from the firm has been in contact with Bondi since she took the helm at the Justice Department.
Under her federal ethics agreement before taking office, Bondi promised that she would not participate 'personally and substantially' in any matter involving former clients at Panza Maurer for one year after she last provided service to the client.
Pfizer isn't the only former client that has raised concerns about a potential conflict of interest for Bondi. The Herald earlier reported that Bondi, before becoming attorney general, had lobbied on behalf of a China-backed refrigerant company called iGas USA which currently has an active lawsuit against the federal government, which is being defended by Justice Department lawyers.
Reading the tea leaves
While the Justice Department doesn't typically make public when it has decided to drop a foreign corruption investigation without seeking a penalty, legal experts say what a company says – or doesn't say – in its financial filings can provide clues.
'If they had language about it and then suddenly there's no language about it, you can probably infer that either the investigation is closed, or they no longer believe that it's material for investors to know,' said William Garrett, who manages a database of foreign corruption cases maintained by Stanford University's law school.
Pfizer isn't the only company that appears to have benefited from the new policies.
Three other companies listed in the Stanford foreign corruption case database – Johnson & Johnson, Toyota and medical device company Stryker – indicated in financial filings this year that the Justice Department had dropped investigations into potential foreign corruption violations by their companies.
In early April, Alina Habba, the acting U.S. Attorney for New Jersey, also dropped charges against executives for Cognizant Technologies, an information technology consulting and outsourcing company, citing Trump's executive order.
President's Trump's pause on new foreign corruption cases was lifted last month, and the department said it would resume bringing new cases but that it would prioritize focusing on the conduct of individuals rather than attributing 'nonspecific' wrongdoing to 'corporate structures.'
The recent foreign corruption investigations involving Pfizer weren't the first time the company's foreign activities came under such scrutiny. In 2012, Pfizer subsidiaries agreed to pay the federal government more than $60 million in penalties and surrendered profits and interest in response to allegations of corruption in a number of different countries.
'Pfizer took short cuts to boost its business in several Eurasian countries, bribing government officials in Bulgaria, Croatia, Kazakhstan and Russia to the tune of millions of dollars,' Mythili Raman, then the principal deputy assistant attorney general at the Justice Department, said of one of the investigations.
More recently, Pfizer disclosed that the foreign corruption units from the Justice Department and the SEC had requested documents connected to the company's activities in Russia in 2019, but the company ceased making any mention of that investigation last year.
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