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.”