On June 9, Deputy US Attorney General Todd Blanche issued a memorandum outlining new guidelines for the enforcement of the Foreign Corrupt Practices Act (FCPA)....more
The US Department of Justice (DOJ) revised its Criminal Division Corporate Enforcement and Voluntary Disclosure Policy (CEP), outlining the benefits a company may earn by voluntarily self-disclosing misconduct, as well as the...more
DOJ Announces Updated White-Collar Enforcement Priorities and Revised Policies -
Earlier this week, the Criminal Division of the US Department of Justice (DOJ) introduced a new white-collar enforcement plan, which sets...more
5/19/2025
/ Anti-Kickback Statute ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
False Claims Act (FCA) ,
Fraud ,
Healthcare Fraud ,
Investment Fraud ,
Securities Fraud ,
Settlement ,
Whistleblowers ,
White Collar Crimes
On May 12, Matthew R. Galeotti, the head of the US Department of Justice’s (DOJ) Criminal Division, announced a new white collar enforcement plan, outlined changes to the Corporate Enforcement and Voluntary Disclosure Policy,...more
Seabrook Rehab Center to Pay $19.75 Million for FCA Violations -
A New Jersey drug and alcohol rehabilitation center, Seabrook, will pay $19.75 million to resolve allegations that it violated the False Claims Act (FCA) by...more
5/12/2025
/ Criminal Prosecution ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Fraud ,
Healthcare Facilities ,
Healthcare Fraud ,
Medicaid ,
Medicare ,
Medicare Fraud ,
Paycheck Protection Program (PPP) ,
Settlement ,
Whistleblowers
On April 2, California Attorney General (AG) Rob Bonta issued an alert reminding businesses operating in California that it is illegal to violate the Foreign Corrupt Practices Act (FCPA)....more
4/10/2025
/ Anti-Corruption ,
Bribery ,
California ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Requirements ,
State Attorneys General ,
Unfair Competition Law (UCL)
During the London InterBank Offered Rate (LIBOR) transition, and post LIBOR’s end date of June 30, 2023, the goal for all should be that (1) the effective interest rates be generally economically equivalent as a result of the...more
3/25/2025
/ Banking Sector ,
Borrowers ,
Final Rules ,
Financial Conduct Authority (FCA) ,
Financial Institutions ,
Financial Markets ,
Financial Regulatory Reform ,
Interest Rates ,
IRS ,
Libor ,
Loans ,
Regulatory Requirements ,
Secured Overnight Funding Rate (SOFR) ,
UK
Following a whistleblower complaint filed by Andrew Hersh in 2020, a Florida businessman, Patrick Walsh, and 10 companies he owned or operated entered into a civil settlement for over $20 million to resolve False Claims Act...more
Jury Clears SuperValu of Liability in Whistleblower FCA Prescription Pricing Case -
A federal jury in Illinois recently found SuperValu not liable in a whistleblower lawsuit that accused the company of overcharging the...more
3/10/2025
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Health Care Providers ,
Healthcare Fraud ,
Kickbacks ,
Medicare ,
Medicare Fraud ,
Prescription Drugs ,
SCOTUS ,
Settlement ,
Whistleblowers
Last week, Attorney General Pamela Bondi issued 14 memoranda outlining new enforcement priorities at the US Department of Justice (DOJ). Notably, DOJ resources will shift away from the Foreign Corrupt Practices Act (FCPA) and...more
2/11/2025
/ Anti-Corruption ,
Attorney General ,
Corporate Governance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Agents Registration Act (FARA) ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Regulatory Requirements ,
White Collar Crimes
On October 1, 2024, the United Kingdom Financial Conduct Authority (UK FCA) phased out ‘Zombie’ LIBOR, as a transitional benchmark, with the move to alternative “risk-free” rates....more
2/6/2025
/ Banks ,
Benchmarks ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement ,
Financial Conduct Authority (FCA) ,
Financial Institutions ,
Financial Regulatory Reform ,
Fraud ,
Interest Rates ,
Libor ,
UK
California Doctor to Pay $3 Million for Insider Trading -
On December 18, a California oncologist agreed to pay the US Securities and Exchange Commission (SEC) $3 million to resolve allegations of insider trading. The SEC...more
12/23/2024
/ Bribery ,
California ,
Civil Monetary Penalty ,
Foreign Agents Registration Act (FARA) ,
Foreign Nationals ,
Insider Trading ,
Motion to Dismiss ,
Quid Pro Quo ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934
Florida Telemarketer Sentenced to 15 Years in Prison for $67 Million Medicare Fraud Scheme -
On December 6, Jose Goyos was sentenced to 15 years in prison for his role in managing a deceptive telemarketing scheme to...more
12/16/2024
/ Beneficiaries ,
Department of Justice (DOJ) ,
Florida ,
Food and Drug Administration (FDA) ,
Insider Trading ,
Investors ,
Medicare Fraud ,
Money Laundering ,
Securities Fraud ,
Sentencing ,
Telemarketing ,
Wire Fraud
This past September, the US Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs (ECCP). The revised guidance reflects the government’s evolving expectations regarding corporate responsibility...more
11/18/2024
/ Anti-Retaliation Provisions ,
Artificial Intelligence ,
Code of Conduct ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Employee Training ,
Incentives ,
NIST ,
Risk Management ,
Technology ,
Whistleblower Hotlines ,
Whistleblowers
New York City Mayor Eric Adams Charged for Accepting Foreign Bribes -
On September 26, New York City Mayor Eric Adams was charged with conspiracy to commit wire fraud, bribery, and two counts of soliciting donations from...more
9/30/2024
/ Bribery ,
Campaign Contributions ,
Coronavirus/COVID-19 ,
Criminal Conspiracy ,
False Claims Act (FCA) ,
Foreign Entities ,
Foreign Nationals ,
Fraud ,
HRSA ,
Identity Theft ,
Kickbacks ,
Medicaid ,
Medical Billing Codes ,
Reimbursements ,
Sentencing ,
Settlement ,
Virus Testing ,
Wire Fraud
In December 2023, US Congress passed a landmark anti-bribery law: the Foreign Extortion Prevention Act (FEPA). FEPA was designed to supplement the Foreign Corrupt Practices Act (FCPA) and expand liability to foreign...more
Walgreens Settles for $106.8 Million Over FCA Violations -
On September 13, the US Department of Justice (DOJ) announced that Walgreens Boots Alliance Inc. and Walgreen Co. (collectively, Walgreens) agreed to pay $106.8...more
9/23/2024
/ Anti-Kickback Statute ,
CVS ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Federal Health Care Programs (FHCP) ,
Kickbacks ,
Medicare Advantage ,
Money Laundering ,
Prescription Drugs ,
Settlement ,
Stark Law ,
Walgreens
DOJ Launches Corporate Whistleblower Awards Pilot Program -
On August 1, the US Department of Justice (DOJ) announced the details of its new Corporate Whistleblower Awards Pilot Program. According to the DOJ, the...more
8/12/2024
/ Bribery ,
Controlled Substances Act ,
DEA ,
Department of Justice (DOJ) ,
Durable Medical Equipment ,
False Claims Act (FCA) ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Health Insurance ,
Healthcare Fraud ,
Internal Reporting ,
Kickbacks ,
Opioid ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
Wire Fraud
Federal Court Dismisses $680 Million FCA Suit -
On July 23, a Maryland federal judge, Ellen L. Hollander, dismissed a $680 million False Claims Act (FCA) suit that was previously revived by the US Supreme Court. The suit...more
Texas Pharmaceutical Marketer Sentenced for $59 Million Medications Fraud Conspiracy -
On July 12, Quintan Cockerell, a Texas pharmaceutical marketer, was sentenced to over two years in prison and ordered to pay more than...more
7/22/2024
/ Conspiracies ,
False Claims Act (FCA) ,
Fraud ,
Hospice ,
Kickbacks ,
Medicaid ,
Medicare ,
Paycheck Protection Program (PPP) ,
Prescription Drugs ,
Sentencing ,
Settlement
Biomedical Company Avoids DOJ Prosecution After First Ever Voluntary Corporate Self-Disclosure of Fraud Under NSD Enforcement Policy -
On May 22, the US Department of Justice (DOJ) announced that it will not prosecute a...more
5/28/2024
/ Biomedical Companies ,
Criminal Conspiracy ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Fraud ,
Healthcare Fraud ,
Medicare ,
National Security ,
Self-Disclosure Requirements ,
Voluntary Disclosure
Testing Facility Settles $2.5 Million Anti-Kickback Lawsuit -
On May 15, the US Attorneys for the Southern District of New York announced that they had settled their civil fraud lawsuit against Balance Diagnostics USA,...more
Numerous regulatory jurisdictions internationally, as well as multiple nongovernmental organizations (NGOs) such as the World Bank, have increasingly used compulsory corporate monitorships as part of their respective...more
On March 12, the Second Circuit affirmed in part and reversed in part a district court dismissal of False Claims Act (FCA) claims predicated on alleged Anti-Kickback Statute (AKS) violations. Adam Hart brought the claims...more
On March 7, at the annual American Bar Association (ABA) National Institute on White Collar Crime, US Deputy Attorney General (DAG) Lisa Monaco announced a new whistleblower program that will provide financial rewards to...more
3/19/2024
/ Attorney General ,
CFTC ,
Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Pilot Programs ,
Regulatory Agenda ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes