Article | June 30, 2026
FCPA Enforcement: Where the Bribery Actually Happened
FCPA enforcement trends analyzed by geography. Discover where bribery risk is concentrated and how it impacts global compliance, investigations and risk management.
July 28, 2025
Director Jason Albert provided pivotal testimony in Roberto Vázquez-Ramos, et al. v. Triple-S Salud, et al., which examined allegations of unfair competition and monopolistic practices involving exclusive provider arrangements under Puerto Rico’s government health plan.
In May 2019, the Plaintiffs—a group of urologists in Puerto Rico’s Western Region—alleged that Triple-S Salud (“Triple-S”), the region’s government health plan insurer, and MSO of Puerto Rico, LLC (“MSO”), entered into exclusive dealing agreements with a competing urology group, Urologics LLC (“Urologics”), in violation of Sections 1 and 2 of the Sherman Act.
Plaintiffs claimed the contracts unlawfully constrained trade, monopolized the market, and restricted access to care for patients under the island’s government health plan (GHP).
In 2015, as part of the competitive bidding process, Triple-S considered proposals from both the Puerto Rico Urology Group, Inc. (PRUG), affiliated with Plaintiffs, and Urologics, affiliated with Defendants. The court noted that “Plaintiffs competed and lost. That is the essence of competition.”1
The Federal District Court of Puerto Rico initially dismissed the case. In 2022, the First Circuit Court reinstated the federal antitrust claims related to Triple-S/Urologics exclusive dealing while dismissing claims involving MSO. The case then focused on whether the exclusive contract harmed consumer access or restricted market competition.
Dr. Albert was retained by Defendants to opine on these claims. He submitted expert written and deposition testimony on liability and damages, concluding that the exclusive contract to Urologics by Triple-S was competitively awarded and did not reduce access to care.
On July 15, 2025, Judge Silvia Carreño-Coll of the Federal District Court of Puerto Rico granted the Defendants’ motion for summary judgment and dismissed the case with prejudice, citing Dr. Albert’s testimony throughout the decision, noting his analysis “suggests that GHP patients in Western Puerto Rico did not have limited access to urological services and procedures.”2 As of this writing, the matter remains subject to potential appeal.
“I am thrilled to have had the opportunity to provide testimony that was helpful for the court,” said Dr. Albert. “I am grateful for the help of my fantastic support team.”
Dr. Albert was supported by team members Pablo Varas, Jessica Serody, Belkys Arbizu, and Mia Sharpe.
FCPA Enforcement: Where the Bribery Actually Happened
FCPA enforcement trends analyzed by geography. Discover where bribery risk is concentrated and how it impacts global compliance, investigations and risk management.
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Eric Poer, a Managing Director in Secretariat’s Global Investigations & Disputes practice, was retained by the U.S. Securities and Exchange Commission (SEC) to serve as their forensic accounting expert in a high-profile securities fraud dispute.