Federal FCPA enforcement action reveals concealed payments, sham consulting agreements, and coordinated influence over medical device purchasing decisions in France
A federal foreign bribery investigation has resulted in a corporate resolution involving Balt SAS, a medical device company headquartered in France, alongside criminal indictments against two individuals accused of participating in a years-long scheme to influence procurement decisions at a state-owned public hospital.
The Justice Department resolved the corporate investigation under its Corporate Enforcement and Voluntary Self-Disclosure Policy after determining that Balt voluntarily disclosed the misconduct, fully cooperated with the investigation, and implemented remediation measures. As part of the resolution, Balt agreed to pay approximately $1.2 million in disgorgement of profits linked to the misconduct.
A parallel resolution was also reached with French financial prosecutors, reflecting coordinated enforcement across jurisdictions.
Separately, a federal grand jury in the Central District of California returned an indictment on March 4, 2026, charging David Ferrera, 58, of Coto de Caza, California, and Marc Tilman, 68, of Belgium, for their alleged roles in the scheme.
According to court documents, between approximately 2017 and 2023, Ferrera, who worked as an executive at Balt’s U.S. subsidiary, and Tilman, who was hired as a consultant, participated in a structured bribery arrangement involving a physician serving in a senior role at a state-owned hospital in France.
The scheme allegedly involved payments made to influence the hospital’s purchasing decisions for medical devices, including endovascular embolization coils and related products.
Prosecutors allege that Ferrera caused the company to issue payments to Tilman in the form of consulting fees and bonuses, knowing that a portion of those funds would be passed to the physician as bribes.
To conceal the nature of the payments, the scheme allegedly relied on sham consulting agreements, fabricated invoices, and the use of personal email accounts rather than official corporate communication channels.
The structure of the alleged conduct reflects a layered financial arrangement designed to distance corporate actors from direct payments while maintaining control over the flow of funds to the intended recipient.
The indictment charges both Ferrera and Tilman with one count of conspiracy to violate the Foreign Corrupt Practices Act, two counts of violating the FCPA, one count of conspiracy to commit money laundering, and two counts of money laundering.
If convicted, each defendant faces up to five years in prison for each bribery-related count and up to 20 years in prison for each money laundering count.
The investigation was conducted by federal authorities with international coordination, reflecting the cross-border nature of the alleged conduct and the involvement of a foreign public institution.
The case highlights the intersection of corporate operations, healthcare procurement systems, and international anti-corruption enforcement, particularly in environments where public institutions control purchasing decisions for specialized medical equipment.
The indictment represents formal allegations. Both defendants are presumed innocent unless proven guilty through the judicial process.
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This is another case where federal authorities were able, with international coordination, to solve a problem and bring those who may be guilty before a court of law. It is always nice to see this type of coordination. This is another of those cases that baffles me to some degree. I don’t know anything about the men who will be facing the judicial process but if they were working in the medical field I would think that they would be making a good enough living to be satisfied. I always wonder why people risk losing everything just for a better car or a nicer house. In any case, I hope these men get a fair hearing and receive an adequate sentence if found guilty.
Another positive thing to take from this bad situation is that that Balt voluntarily disclosed the misconduct. Then they fully cooperated with the investigation and implemented remediation measures. They were also willing to pay approximately $1.2 million in disgorgement of profits linked to the misconduct. A company like that is concerned about its future and is willing to invest in it. Kudos to those in management who made these decisions.
Thank you for the article.
You’re very welcome, Chris.
You’re right to point out the value of international coordination in cases like this. These types of investigations don’t come together without sustained effort across multiple jurisdictions, and that level of alignment is becoming more critical as these schemes cross borders.
On your point about motivation, that’s something that comes up often. The risk versus reward doesn’t always align logically from the outside. In many of these cases, it’s less about necessity and more about access, opportunity, and decisions made over time that escalate beyond control.
You also made a strong observation about Balt’s response. Voluntary disclosure, cooperation, and remediation do reflect a company looking to stabilize and move forward rather than resist accountability. That distinction matters in how these cases are handled. It’s also understandable to question why individuals who are already well-compensated take these risks. In many cases, it comes down to greed, or decisions that move beyond financial incentive into something more calculated.
Thanks again, Chris, for your insight and for taking the time to read and comment. I hope you have a great night and day ahead. 😎
You’re welcome, John, and thank you for this thoughtful response. There is a good chance that greed was involved. It is such a problem in society today. I’m glad this will be resolved and I hope Balt will thrive because of good decisions like this.
Thank you for your kind words, John. I hope you are having a great day! 😊