As a result of that settlement, the drugmaker signed a five-year Corporate Integrity Agreement, which required establishing an internalcomplianceprogram and reporting violations, among other things ( read more here).
There turn out to be at least six different facets to this approach: the establishment of an internalcomplianceprogram, bona fide market making, reasonably expected near-term demands of clients, registration under securities or commodities laws, revenue from fees and commission, etc.