08-02 (June 13, 2008), available at http ://www.justice.gov/criminal/fraud/fcpa/ opinion/2008/0802.pdf; see also Press Release, US. Dept. of Justice, Pfizer H.C.P. Corp. Agrees to Pay $15 Million Penalty to Resolve Foreign Bribery Investigation (Aug. 7, 2012) (“In the 18 months following its acquisition of Wyeth, Pfiz