The Department of Justice announced today a resolution of a foreign bribery investigation into Balt SAS (Balt), a medical device company headquartered in France, relating to an alleged scheme to pay bribes to a physician who served in a senior role at a state-owned public hospital in France (the Official), in violation of the Foreign Corrupt Practices Act (FCPA). Pursuant to the resolution, under Part I of the Justice Department’s Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), because Balt voluntarily self-disclosed the misconduct, fully cooperated with the Department’s investigation, and timely and appropriately remediated the wrongdoing, the Department declined to prosecute Balt, which agreed to pay approximately $1.2 million in disgorgement. In addition to the Department’s enforcement action, the Parquet National Financier (PNF) in France entered into a coordinated resolution with Balt following a court hearing earlier today.
Separately, a federal grand jury in the Central District of California returned an indictment on March 4, 2026, charging two businessmen for their roles in the alleged years-long criminal scheme. David Ferrera, 58, of Coto de Caza, California, worked as an executive at Balt’s U.S. subsidiary. Marc Tilman, 68, of Belgium, was hired by Balt’s U.S. subsidiary as a consultant. According to court documents, between approximately 2017 and continuing into 2023, Ferrera, Tilman, and others allegedly paid bribes to the Official in order for the Official to cause the hospital to purchase medical devices – specifically, endovascular embolization coils and ancillary products – from Balt. As alleged, Ferrera caused Balt to make corrupt payments – disguised as purported consulting fees and bonuses – to Tilman, knowing that Tilman would pay a portion of those funds to the Official as bribes. To conceal the scheme, the co-conspirators allegedly used sham consulting agreements, fake invoices, and personal email accounts.
“Today’s resolution – the first ever under the Department-wide Corporate Enforcement Policy – demonstrates the value of voluntarily self-reporting wrongdoing to the Department of Justice,” said Assistant Attorney General A. Tysen Duva of the Justice Department’s Criminal Division. “This corporate resolution, which is coordinated with our foreign partners at the PNF in France, credits Balt’s self-report to the Department as well as its full cooperation and timely remediation. Our related indictment of two individuals associated with Balt demonstrates the Criminal Division’s unwavering pursuit of culpable individuals that engage in corrupt conduct.”
“Ferrera and Tilman allegedly conspired to pay bribes to a French physician, who in turn caused a hospital in France to purchase medical devices from their company,” said Assistant Director in Charge Darren Cox of the FBI Washington Field Office. “Let their indictment serve as a testament to the FBI’s long reach. When corruption extends beyond our borders, the FBI works with our international partners to bring individuals to justice.”
The Department declined prosecution of Balt based on an assessment of the factors set forth in the Department-wide CEP and the Principles of Federal Prosecution of Business Organizations (Justice Manual 9-28.300), including, but not limited to: (1) Balt’s timely and voluntary self-disclosure of the misconduct, which was identified during an internal investigation that was ongoing at the time of the disclosure; (2) Balt’s full and proactive cooperation in this matter (including its provision of all known relevant facts of the misconduct and information regarding the individuals involved) and its agreement to continue to cooperate with any ongoing Department investigations and any prosecutions that have resulted or might result in the future; (3) the nature and seriousness of the offense; (4) Balt’s timely and appropriate remediation, including disciplinary action against relevant personnel, termination of the business relationships that gave rise to the misconduct, tailored compliance training for Balt senior management, and improvements to its compliance program and internal controls; (5) the absence of aggravating circumstances that, when weighed against Balt’s voluntary self-disclosure, cooperation, and remediation, would warrant a disposition other than a resolution under Part I of the CEP; (6) Balt’s acceptance of responsibility for the criminal conduct and entry into a parallel resolution with authorities in France, which will also include corporate compliance requirements imposed under the French system; and (7) that Balt agrees to disgorge the amount of its ill-gotten gains.
Ferrera and Tilman are each 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. If convicted, each faces a maximum penalty of five years in prison for each of the bribery conspiracy and bribery charges and 20 years in prison for each of the money laundering conspiracy and money laundering charges.
The FBI Washington Field Office is investigating the case.
Fraud Section Trial Attorney Patrick Brown and Senior Counsel Peter Cooch of the Criminal Division are prosecuting the case.
The Fraud Section is responsible for investigating and prosecuting FCPA and Foreign Extortion Prevention Act (FEPA) matters. Additional information about the Justice Department’s FCPA and FEPA enforcement efforts can be found at www.justice.gov/criminal/fraud/fcpa .
An indictment is merely an allegation. All defendants are presumed innocent until proven guilty beyond a reasonable doubt in a court of law.