Pfizer subsidiaries in multiple countries, including Italy and Russia, were accused by the SEC in 2012 of paying bribes over about a decade to foreign officials to secure regulatory and formulary approvals, boost sales, and increase prescriptions, [an] SEC complaint shows. In China, one subsidiary allegedly created "points programs" that let doctors earn gifts based on prescribing its medications, according to the SEC, while in Croatia, another offered a "bonus program" that reportedly rewarded doctors with cash, international travel, or free products. Pfizer and an indirect subsidiary agreed to pay more than $45 million in separate settlements, without admitting or denying the allegations, the SEC reported. In a parallel action, Pfizer H.C.P., an indirect, wholly-owned healthcare-focused subsidiary, agreed to pay a $15 million penalty to resolve its investigation of FCPA violations after admitting to improper payments to foreign government officials, according to the U.S. Department of Justice. And in Greece, Poland, and Romania, Johnson & Johnson subsidiaries, employees, and agents were accused by regulators of using slush funds, sham contracts, and off-shore companies in the Isle of Man to reward doctors and administrators who ordered or prescribed its products, including surgical implants. The 2011 SEC complaint also accused the company of paying kickbacks in Iraq to obtain business.