Letter to Senate Judiciary Committee Requesting Oversight Hearing into AG Pam Bondi’s Pfizer Conflicts
Senate Judiciary Letter - AG Pam Bondi/Pfizer Conflicts
June 9, 2025
Chair Grassley and Ranking Member Durbin
Senate Judiciary Committee
224 Dirksen Senate Office Building
Washington, DC 20510
Dear Chair Grassley and Ranking Member Durbin:
Following up on my testimony before you at Attorney General Pam Bondi’s confirmation hearing in January[1], I write to provide you with concerning new information that calls into question whether she has abided by the following commitment she made in her DOJ Ethics Agreement: “In the event that an actual or potential conflict of interest arises during my appointment, I will consult with an agency ethics official and take the measures necessary to resolve the conflict, such as recusal from the particular matter or divesture of an asset.”[2]
- AG Bondi’s work for Pfizer: According to her Public Financial Disclosure Report filed in January, AG Bondi recently represented pharmaceutical company Pfizer.[3] AG Bondi disclosed that she provided “legal services” to Pfizer through the law firm Panza, Maurer & Maynard, where she stated she has served as “Of Counsel” since June 2021.[4] AG Bondi reported receiving $203,738 in income last year from Panza, Maurer & Maynard and disclosed the name of only one client as a source of her compensation at Panza: [5] She did not disclose what particular legal matters she worked on for Pfizer and, to my knowledge, has not yet disclosed any other information about her Pfizer work.
- Pfizer’s SEC filing in November 2024 disclosed DOJ Foreign Corrupt Practices Act Inquiries into Pfizer’s operations in China and Mexico: On the day before the November 2024 presidential election, Pfizer disclosed in a securities filing with the SEC that it had been the subject of two DOJ Foreign Corrupt Practices Act (FCPA) Unit inquiries into its operations: one in China and one in Mexico.[6] Pfizer originally disclosed the DOJ FCPA Unit inquiry into its China operations in August 2020 and continued to disclose it in subsequent SEC filings through November 2024.[7] Pfizer originally disclosed it was the subject of a DOJ FCPA Unit inquiry into its Mexico operations in May 2023 and continued to disclose it in subsequent SEC filings through November 2024.[8] In both cases, Pfizer disclosed that it had “received an informal request from the U.S. Department of Justice’s FCPA Unit seeking documents relating to our operations” and that Pfizer had “produced records pursuant to this request.”
- Pfizer was previously investigated by DOJ for violations of the FCPA and agreed in 2012 to pay a $15 Million Penalty to Resolve a DOJ Foreign Bribery Investigation.[9] While no details have been publicly disclosed about the recent DOJ FCPA inquiries into Pfizer’s operations in China and Mexico, Pfizer was previously the subject of DOJ FCPA investigations. In August 2012, a Pfizer subsidiary signed a Deferred Prosecution Agreement with DOJ to settle charges alleging that some of its foreign subsidiaries had bribed doctors and health care officials in order to gain regulatory approval for its drugs and boost drug sales in Bulgaria, Croatia, Kazakhstan, and Russia.[10] The DOJ press release about this stated: “Corrupt pay-offs to foreign officials in order to secure lucrative contracts creates an inherently uneven marketplace and puts honest companies at a disadvantage.”[11]
- AG Bondi and President Trump’s February 2025 Directives Affecting DOJ FCPA Investigations and Enforcement Actions. On February 5, 2025, the day after being confirmed, AG Bondi issued a memorandum to all DOJ Department Employees that included a section titled “Foreign Corrupt Practices Act.”[12] In that section of her memo, AG Bondi directed the DOJ FCPA Unit to “shift focus away” from FCPA investigations and cases that do not involve a connection to cartels and transnational criminal organizations.[13] The Stanford Law School FCPA Clearinghouse in its 2025 Q1 Report described the major impact of Bondi’s action: “If the new FCPA enforcement guidelines follow the direction of the Bondi Memo, then the new guidelines would represent a major shift in FCPA enforcement policies.”[14] According to another analysis, AG Bondi’s “decision to scale back on white-collar FCPA enforcement is expected to have far-reaching implications . . . By shifting resources away from traditional corporate cases, the Justice Department may be signaling a reduced appetite for holding multinational corporations accountable for illicit payments made to secure business advantage.”[15] Five days after AG Bondi’s memo, President Trump issued an Executive Order instructing the AG to cease initiation of new FCPA investigations or enforcement actions unless the AG determines an exception should be made, review in detail all existing FCPA investigations or enforcement actions, take action to “restore proper bounds” on FCPA enforcement, and issue updated FCPA investigation and enforcement guidelines.[16]
- Pfizer’s 2025 SEC filings have not included disclosure of any DOJ Foreign Corrupt Practices Act Inquiries into Pfizer’s operations in China and Mexico. Following AG Bondi and President Trump’s FCPA Directives, Pfizer filed a securities filing on February 27, 2025 that did not include mention of any DOJ FCPA Inquiries into its operations in China and Mexico.[17] This was the first such filing since 2020 in which Pfizer did not mention any DOJ FCPA inquiries into its operations. On May 5, 2025, Pfizer’s quarterly filing also did not mention DOJ FCPA Inquires into its operations in China and Mexico.[18]
- Questions raised:
- What happened to the DOJ FCPA Unit’s inquiries into Pfizer’s operations in China and Mexico between November 2024 and February 2025?
- Did AG Bondi’s work for Pfizer involve DOJ’s FCPA inquiries into Pfizer?
- What DOJ ethics official or OGE official, if any, did AG Bondi consult with to determine whether she should recuse herself from issuing the directive about DOJ FCPA Unit activities that could have affected the inquiries into Pfizer?
- Has AG Bondi recused herself from reviewing the DOJ FCPA Unit inquiries into Pfizer’s operations and from all actions that could affect Pfizer?
- Has anyone who reports to AG Bondi met or communicated with Pfizer’s representatives?
Given these concerning questions about AG Bondi’s former client Pfizer and the status of FCPA inquiries into Pfizer by the Department of Justice she now leads, I request that you schedule an oversight hearing as soon as possible to get answers for the American people.
Sincerely,
Lisa Gilbert
Co-President
Public Citizen
cc: All Members, Senate Judiciary Committee
[1] Written Testimony for the Record submitted by Lisa Gilbert, Co-President, Public Citizen, January 16, 2025; https://www.judiciary.senate.gov/imo/media/doc/2025-01-16_-_testimony_-_gilbert.pdf; Senate Question for the Record from Senator Adam Schiff to Lisa Gilbert; https://www.judiciary.senate.gov/imo/media/doc/2025-01-16_-_qfr_responses_-_gilbert.pdf
[2] Pam Bondi Ethics Agreement, signed January 14, 2025: https://extapps2.oge.gov/201/Presiden.nsf/PAS+Index/FC3B6F6F496E257B85258C150032F344/$FILE/Bondi%2C%20Pam%20%20finalEA.pdf; see also Pam Bondi Ethics Agreement Compliance Certification, signed May 5, 2025; https://extapps2.oge.gov/201/Presiden.nsf/PAS+Index/3CDD529EC3045A9785258C84002C1259/$FILE/Bondi%20EA%20Certification%201%20of%201.pdf
[3] Pam Bondi Public Financial Disclosure Report, signed January 3, 2025; https://extapps2.oge.gov/201/Presiden.nsf/PAS+Index/ABF60CD8EC97BBB585258C150032DCB2/$FILE/Bondi%2C%20Pam%20%20final278.pdf
[4] Id.
[5] Id.
[6] Pfizer Form 10-Q SEC Quarterly Report, 11/4/24; https://d18rn0p25nwr6d.cloudfront.net/CIK-0000078003/d75e0656-52a6-49db-a07f-94348b65f41a.pdf
[7] Pfizer Form 10-Q SEC Quarterly Report, 8/6/20, p. 39 (“U.S. Department of Justice Inquiry relating to China Operations. In June 2020, we received an informal request from the U.S. Department of Justice’s FCPA Unit seeking documents relating to our operations in China. We will be producing records pursuant to this request.”); https://d18rn0p25nwr6d.cloudfront.net/CIK-0000078003/d3a3bbbe-3a3c-438a-9592-7a708cabe130.pdf
[8] Pfizer Form 10-Q SEC Quarterly Report, 5/10/23, p. 30 (“U.S. Department of Justice Inquiry relating to Mexico Operations. In March 2023, we received an informal request from the U.S. Department of Justice’s FCPA Unit seeking documents relating to our operations in Mexico. We are producing records pursuant to this request.”); https://d18rn0p25nwr6d.cloudfront.net/CIK-0000078003/4b5a2227-c4e1-48c5-9544-b38b89703529.pdf
[9] “Pfizer H.C.P. Corp. Agrees to Pay $15 Million Penalty to Resolve Foreign Bribery Investigation,” U.S. Department of Justice Press Release, 8/7/12; https://www.justice.gov/archives/opa/pr/pfizer-hcp-corp-agrees-pay-15-million-penalty-resolve-foreign-bribery-investigation; In a parallel action, the SEC negotiated a separate settlement with Pfizer and with Wyeth, which Pfizer had purchased, for a total of $45 million, see: “SEC Charges Pfizer with FCPA Violations” 8/7/12; https://www.sec.gov/newsroom/press-releases/2012-2012-152htm
[10] Deferred Prosecution Agreement between Pfizer H.C.P. Corporation and the United States of America, 8/7/12; https://www.justice.gov/sites/default/files/criminal-fraud/legacy/2012/08/15/2012-08-07-pfizer-dpa.pdf; Pfizer agrees to pay $60M to settle foreign bribery case, Washington Post, 8/7/12; https://www.washingtonpost.com/business/economy/pfizer-agrees-to-pay-60m-to-settle-foreign-bribery-case/2012/08/07/a2426f5e-e0b6-11e1-8fc5-a7dcf1fc161d_story.html
[11] Pfizer H.C.P. Corp. Agrees to Pay $15 Million Penalty to Resolve Foreign Bribery Investigation, U.S. Department of Justice Press Release, 8/7/12; https://www.justice.gov/archives/opa/pr/pfizer-hcp-corp-agrees-pay-15-million-penalty-resolve-foreign-bribery-investigation
[12] Memorandum for All Department Employees From The Attorney General – Total Elimination of Cartels and Transnational Criminal Organizations, February 5, 2025; https://www.justice.gov/ag/media/1388546/dl?inline
[13] Id., p. 4; see also Bondi Diminishes Justice Department White Collar Enforcement, Bloomberg Law, 2/5/25; https://news.bloomberglaw.com/us-law-week/bondi-scales-back-us-justice-department-white-collar-enforcement
[14] 2025 Q1 Report, Stanford Law School Foreign Corrupt Practices Act Clearinghouse, p. 5; https://fcpa.stanford.edu/fcpac-reports/2025-fcpa-q1-report.pdf
[15] “Bondi Pivots Justice Department’s Stance on White Collar Under Trump,” Anderson P.C. Law Firm; https://anderpc.com/insights/bondi-pivots-justice-departments-stance-on-white-collar-under-trump
[16] Presidential Executive Order “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security,” 2/10/25; https://www.whitehouse.gov/presidential-actions/2025/02/pausing-foreign-corrupt-practices-act-enforcement-to-further-american-economic-and-national-security/
[17] Pfizer Form 10-K SEC Annual Report, 2/27/25; https://d18rn0p25nwr6d.cloudfront.net/CIK-0000078003/58225110-35f3-46df-a207-d87bb30eaedd.pdf
[18] Pfizer Form 10-Q SEC Quarterly Report, 5/5/25; https://d18rn0p25nwr6d.cloudfront.net/CIK-0000078003/6be0bc09-ff03-4e04-9b54-13ceb601b05e.pdf