compliance officer for the biotech start-up company. In preparation for launching the company's first clinical trial, you have been asked to draft a memo explaining whether, and if so under what circumstances, payments made to clinical investigators will need to be disclosed, either publicly or to a regulatory agency. The upcoming trial will involve investigators in the U.S. and France, and the company ultimately intends to seek marketing authorization for its product in both the U.S. and the E.U.