On January 8, 2021, US authorities announced that they reached an agreement with Deutsche Bank Aktiengesellschaft (Deutsche Bank) to resolve the government’s investigation into violations of the Foreign Corrupt Practices Act...more
1/21/2021
/ Anti-Corruption ,
Commodities ,
Compensation ,
Criminal Penalties ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Deutsche Bank ,
Disgorgement ,
False Reporting ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Fraud ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Third-Party Risk
New York Pharmacy Owners Charged in $30 Million COVID-19 Health Care Fraud and Money Laundering Case -
On December 21, 2020, the Department of Justice (DOJ) announced that two owners of over a dozen New York-area...more
1/11/2021
/ California ,
Coronavirus/COVID-19 ,
Criminal Convictions ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Genetic Testing ,
Healthcare Fraud ,
Identity Theft ,
Medicare ,
Money Laundering ,
New York ,
Pharmacies ,
Pharmacist ,
State Attorneys General ,
Tennessee ,
Wire Fraud
False Claims Act Legal Developments -
First Circuit Upholds Whistleblower Retaliation Verdict -
On December 9, 2020, the US Court of Appeals for the First Circuit held as a matter of first impression that “the...more
12/21/2020
/ Anti-Corruption ,
Appeals ,
Bribery ,
Conspiracies ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
Qui Tam ,
Retaliation ,
Title VII ,
Venezuela ,
Whistleblower Protection Policies ,
Whistleblowers
HHS Announces Formation of FCA Working Group -
On December 4, 2020, the US Department of Health and Human Services (HHS) announced that it is creating a False Claims Act Working Group to enhance the partnership between...more
12/14/2020
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Civil Monetary Penalty ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Fraud ,
Healthcare Fraud ,
Integrity Policies ,
Medicare ,
OIG ,
Proposed Rules ,
SCOTUS ,
Settlement Agreements ,
Stark Law ,
Value-Based Care ,
Working Groups
Seven Individuals Charged in $16 Million COVID-Relief Fraud Scheme -
In an indictment unsealed on November 17, seven individuals were charged with conspiracy to commit wire fraud and wire fraud for allegedly submitting at...more
House Committee Chairs Direct White House and Federal Agencies to Preserve Documents during Transition Period to the Biden Administration -
On November 10, 2020, Committee Chairs from the House of Representatives sent...more
Mortgage Company to Pay $24.9 Million to Resolve Alleged False Claims Act Violations -
On October 28, 2020, the Department of Justice (the “DOJ”) announced that Guild Mortgage Company (“Guild”), a California-based...more
11/2/2020
/ Anti-Bribery ,
Books & Records ,
Department of Justice (DOJ) ,
Fair Housing Act (FHA) ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
HUD ,
India ,
Internal Controls ,
Maryland ,
Money Laundering ,
Russia ,
Settlement ,
Wire Fraud
Department of Justice Announces $8.3 Billion Settlement with Opioid Manufacturer Purdue Pharma and Members of the Sackler Family -
On October 21, the Department of Justice (DOJ) announced that it reached a global resolution...more
10/26/2020
/ Anti-Kickback Statute ,
Bankruptcy Court ,
DEA ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Federal Food Drug and Cosmetic Act (FFDCA) ,
Fraud ,
Health Care Providers ,
Opioid ,
Pharmaceutical Industry ,
Purdue Pharma ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
Substance Abuse
DOJ Announces Charges Against 345 Defendants in Historic Nationwide Health Care Fraud and Opioid Takedown -
The DOJ announced a nationwide enforcement action charging 345 defendants across 51 federal districts with...more
10/5/2020
/ Anti-Dumping Agreement ,
Bribery ,
Coronavirus/COVID-19 ,
Countervailing Duties ,
Department of Justice (DOJ) ,
Economic Injury Disaster Loans ,
False Claims Act (FCA) ,
Healthcare Fraud ,
Kickbacks ,
Loan Applications ,
Medicare ,
Nonprofits ,
Opioid ,
Pharmacies ,
Physicians ,
SBA ,
Settlement ,
Substance Abuse ,
Telecommunications ,
Telemedicine ,
Wire Fraud
On September 29, 2020, US authorities announced that they reached an agreement with JPMorgan Chase & Co. (JPMorgan Chase) to settle criminal charges related to two distinct years-long market manipulation schemes involving...more
10/2/2020
/ CFTC ,
Compliance ,
Criminal Penalties ,
Department of Justice (DOJ) ,
Disgorgement ,
DPA ,
FCPA Guidance ,
Foreign Corrupt Practices Act (FCPA) ,
JPMorgan Chase ,
Market Manipulation ,
Restitution ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
Spoofing ,
U.S. Treasury
Acute Care Hospital Agrees to Pay $50 Million to Settle Alleged Stark Law and Anti-Kickback Statute Violations -
On September 9, 2020, the Department of Justice (“DOJ”) announced that Wheeling Hospital Inc. (“Wheeling...more
9/14/2020
/ Anti-Kickback Statute ,
California ,
Campaign Contributions ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Fair Market Value ,
False Claims Act (FCA) ,
Fraud ,
Medicaid ,
Medicare ,
Qui Tam ,
Risk Assessment ,
Settlement Agreements ,
Stark Law ,
TRICARE ,
Wire Fraud
Third Circuit Holds that False Claims Act First-to-File Bar is Not Jurisdictional -
On September 1, 2020, the US Court of Appeals for the Third Circuit held that the False Claims Act (FCA) first-to-file bar, 31 U.S.C. §...more
9/8/2020
/ Anti-Bribery ,
Appeals ,
Appellate Courts ,
Burden of Proof ,
Civil Forfeiture ,
Department of Justice (DOJ) ,
Embezzlement ,
Extradition ,
Failure To State A Claim ,
False Claims Act (FCA) ,
Financial Institutions ,
First-to-File ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Lobbying ,
Settlement Agreements
DOJ Issues First FCPA Advisory Opinion Since 2014 -
On August 14, the DOJ issued its first advisory opinion on the Foreign Corrupt Practices Act (FCPA) in six years. The DOJ’s opinion release process allows companies to...more
Drug Testing Lab Pays Nearly $12 Million to Settle False Claims Act Allegations -
On July 20, 2020, the Department of Justice (DOJ) announced a civil settlement with Sterling Healthcare Opco, LLC d/b/a Cordant Health...more
7/27/2020
/ Anti-Fraud Provisions ,
Anti-Kickback Statute ,
Corporate Integrity Agreement ,
Department of Justice (DOJ) ,
Drug Testing ,
False Claims Act (FCA) ,
Fraud ,
Inspector General ,
Kickbacks ,
Medicare ,
Securities and Exchange Commission (SEC) ,
TRICARE
COVID Relief Program Fraud Charges -
DOJ continues to announce charges against defendants accused of fraud in connection with allegedly false loan applications submitted under the Paycheck Protection Program (PPP)...more
7/20/2020
/ Bank Fraud ,
CARES Act ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
False Statements ,
Fraud ,
Healthcare Fraud ,
Kickbacks ,
Loan Applications ,
Medicaid ,
Medicare ,
Paycheck Protection Program (PPP) ,
SBA ,
Skilled Nursing Facility ,
Tax Returns ,
TRICARE ,
Wire Fraud
DOJ Announces $72.3 Million False Claims Act Settlement -
Oklahoma Center for Orthopaedic and Multi-Specialty Surgery, its part-owner and management company, a physician group, and other affiliated entities and individuals...more
SBA and Department of Treasury Announce Disclosure of PPP Recipients -
After weeks of mounting public and congressional pressure, on Friday, June 19, the SBA and Department of Treasury announced that it will make...more
6/26/2020
/ Department of Justice (DOJ) ,
Disclosure ,
Financial Institutions ,
Food and Drug Administration (FDA) ,
Fraud ,
Kickbacks ,
NAICS ,
Paycheck Protection Program (PPP) ,
Prescription Drugs ,
SBA ,
TRICARE ,
U.S. Treasury ,
Wire Fraud
Medical Technology Company President Charged in $69 Million COVID-19 Testing Fraud Scheme -
A complaint in the Northern District of California was unsealed on June 9, 2020, charging the president of Arrayit Corporation, a...more
6/15/2020
/ Alaska Native Claims Settlement Act (ANCSA) ,
Coronavirus/COVID-19 ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Fraud ,
General Services Administration (GSA) ,
Kickbacks ,
Medicare ,
Pharmacies ,
Probation ,
Securities Fraud ,
South Korea ,
TRICARE ,
US Army Corps of Engineers ,
Virus Testing ,
Wire Fraud
Contractors to Pay Over $2.8 Million to Settle Small Business Contract Fraud Allegations -
On June 2, 2020, the Department of Justice announced that Ross Group Construction Corporation and its affiliates agreed to pay...more
6/5/2020
/ Blockchain ,
California ,
Compliance ,
Contractors ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Fraud ,
Initial Coin Offering (ICOs) ,
Publicly-Traded Companies ,
SBA ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Small Business ,
USDA
Foreign National Charged With Fraudulently Applying for $20 Million in COVID-19 Loans -
On May 21, 2020, the US Attorney’s Office for the Southern District of New York announced the arrest of a foreign national for...more
DOJ Obtains Restraining Order to Stop Oklahoma Company From Selling Purported COVID-19 Treatment -
An Oklahoma federal court issued a temporary restraining order against Xephyr LLC d/b/a N-Ergetics and its owners ordering...more
DOJ Files First Fraud Case in Connection with the CARES Act SBA Paycheck Protection Program -
David Staveley and David Butziger are the first two individuals to be charged with allegedly defrauding the Coronavirus Aid,...more
Nonprofit Hospital System and Physician Practice Reach $10 Million Settlement for False Claims Act Allegations -
Centra Health Inc., a nonprofit hospital system, and Blue Ridge Ear, Nose, Throat and Plastic Surgery, Inc.,...more
4/27/2020
/ Anti-Kickback Statute ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Kickbacks ,
Maryland ,
Medicaid ,
New York ,
Patient Referrals ,
Qui Tam ,
Relators ,
Stark Law ,
State and Local Government ,
Tax Fraud ,
Whistleblower Awards ,
Whistleblowers
DOJ Freezes Collection Of Civil Penalties to Blunt Economic Impact of COVID-19 -
The US Department of Justice has paused its collection of civil penalty payments until at least May 31, “in an effort to blunt the...more
Supreme Court Declines to Resolve Circuit Split Over Deference Owed to Department of Justice Decisions to Dismiss Whistleblower Suits Brought Under the False Claims Act -
On April 6, 2020, the US Supreme Court denied a...more