The U.S. Department of Justice recently declined to prosecute Balt SAS, a medical device company headquartered in France, for its alleged role in a scheme to pay bribes to a senior-level employee at a state-owned and state-controlled public hospital in France. On March 19, 2026, the DOJ announced that it had reached a resolution with Bart under Part I of the DOJ’s Corporate Enforcement and Voluntary Self-Disclosure Policy, which covers voluntary self-disclosures by companies. As part of the declination, Balt agreed to pay disgorgement.
According to the declination letter dated March 17, 2026, DOJ found evidence that Balt paid approximately $602,000 in bribes to a senior-level physician at a state-owned hospital in France between approximately 2017 and 2023. According to DOJ, the bribes were paid through a third-party consultant in Belgium to persuade the hospital to purchase certain medical devices from Balt, namely endovascular embolization coils. The DOJ also found that Balt attempted to conceal the bribe payments using fake invoices and purported “bonus” payments. The DOJ stated that Balt generated approximately $1.6 million in revenue and $1.2 million in profits from the scheme.
According to the DOJ, its decision not to prosecute was based on several factors, including (i) Balt’s voluntary self-disclosure of misconduct, (ii) its full cooperation with DOJ’s investigation, which included providing “all known relevant facts of the misconduct and information regarding the individuals involved,” (iii) the “nature and seriousness of the offense,” and (iv) Balt’s timely and appropriate remediation of the misconduct, which included disciplinary action, termination of certain business relationships, “tailored compliance training,” and additional improvements to the Company’s compliance program. As part of the settlement, Balt agreed to pay disgorgement of $1,214,797, the amount of profit DOJ calculated for the sale of endovascular coils and ancillary products to the hospital. The DOJ also reported that Balt entered into a coordinated resolution with the Parquet National Financier (PNF) in France on the same day.
The resolution comes just weeks after a federal grand jury in California indicted David Ferrera and Marc Tilman, two of Bart’s former owners, on March 4, 2026, for their alleged roles in a bribery and money laundering scheme involving a government official at the Centre Hospitalier Universitaire de Reimes, a state-owned and state-controlled public university hospital in France. The former executives are accused of using sham consulting agreements and fake invoices to disguise the bribe payments as “bonus” payments. They are also accused of attempting to conceal the scheme by using personal email accounts and encrypted messaging applications to communicate about the scheme, as well as using coded language to refer to bribe payments and payment amounts. Ferrera, a U.S. citizen, and Tilman, a citizen of Belgium, have each been charged with one count of conspiracy to violate the FCPA, two counts of violating the FCPA, one count of conspiracy to commit money laundering, and two counts of money laundering.
DOJ Press Release | DOJ Letter to Balt