Balt SAS voluntarily reported a years-long bribery scheme involving a French hospital. The company avoided prosecution. Two of its U.S.-based businessmen were not so lucky.

In a example of the Justice Department’s carrot-and-stick approach to corporate crime, a French medical device maker walked away from a foreign bribery investigation without criminal charges—while two of its own executives now face decades in prison.

The Department of Justice announced Thursday that it has declined to prosecute Balt SAS, a French manufacturer of endovascular embolization coils and related products, after the company voluntarily self‑disclosed a scheme to bribe a senior physician at a state‑owned hospital in France. Balt agreed to pay approximately $1.2 million in disgorgement and will continue to cooperate with ongoing investigations.

Hours earlier, a French court entered a parallel resolution with Balt coordinated by the Parquet National Financier (PNF), marking one of the first cross‑border resolutions of its kind.

But for two individuals tied to the scheme, the outcome was far different.

A Scheme Disguised as Consulting Fees

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, with conspiracy to violate the Foreign Corrupt Practices Act (FCPA), substantive FCPA violations, and money laundering charges.

According to court documents, between approximately 2017 and 2023, Ferrera—an executive at Balt’s U.S. subsidiary—and Tilman—a consultant hired by that subsidiary—allegedly orchestrated bribes to a physician who held a senior role at a French public hospital. The goal: induce the official to steer the hospital’s purchases of medical devices to Balt.

The mechanics of the alleged scheme were designed to avoid scrutiny. Ferrera caused Balt to make payments to Tilman, disguising them as “consulting fees” and bonuses. Tilman, in turn, passed a portion of the funds to the physician as bribes. To conceal the trail, the conspirators used sham consulting agreements, fake invoices, and personal email accounts.

“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 Darren Cox, Assistant Director in Charge 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.”

While the individuals face potential prison time, Balt itself benefited from a relatively new Department policy: the Corporate Enforcement and Voluntary Self‑Disclosure Policy (CEP) .

The DOJ said Balt’s case marks the first time the department has resolved an FCPA investigation using Part I of the CEP—the most favorable tier of the policy, reserved for companies that voluntarily self‑disclose misconduct, fully cooperate, and timely and appropriately remediate.

According to the department, Balt did all three:

Self‑disclosed the misconduct after uncovering it during an internal investigation.
Fully cooperated, providing all known relevant facts and information about the individuals involved.
Remediated by taking disciplinary action against personnel, terminating the business relationships that gave rise to the misconduct, providing tailored compliance training to senior management, and strengthening its internal controls.

“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 A. Tysen Duva, Assistant Attorney General 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.”

Under the French resolution, Balt will also face ongoing compliance requirements under the French legal system.

What’s Next for the Individuals

Ferrera and Tilman remain charged with:

One count of conspiracy to violate the FCPA
Two counts of violating the FCPA
One count of conspiracy to commit money laundering
Two counts of money laundering

If convicted, each faces a statutory maximum of five years in prison for each of the bribery‑related charges and 20 years for each of the money laundering charges. An indictment is merely an allegation; all defendants are presumed innocent until proven guilty beyond a reasonable doubt in a court of law.

For Balt, the path forward involves disgorgement, compliance oversight, and a lesson that self‑disclosure can be a lifeline. For the two men indicted, the legal fight is just beginning.

This article is based on a March 19, 2026, announcement by the U.S. Department of Justice. Additional context about the Corporate Enforcement Policy and parallel French resolution is drawn from the DOJ’s public release.