In its latest filing with the Securities and Exchange Commission (SEC) for the quarter ending July 2011, Pfizer indicated that it has voluntarily provided the SEC and the Department of Justice (DOJ) with information concerning potentially improper payments made by Pfizer and Wyeth in connection with sales activities that took place outside of the United States.

Pfizer also says in the filing that it is in discussion with the DOJ and the SEC regarding a resolution of these matters. Pfizer also disclosed that other potentially improper payments are the subject of investigation by government authorities in other countries, including a tax investigation being conducted in Germany related to a wholly owned subsidiary of Pfizer.

If SEC finds that the improper payments constituted bribery, it could be costly for Pfizer. Earlier this month, Johnson & Johnson (J&J) agreed to pay $70 million to settle bribery charges brought by the SEC. J&J was charged with bribing public doctors in Greece, Poland, and Romania, as well as paying kickbacks in Iraq to obtain contracts under the Oil for Food Program.