On July 8, the US Department of Justice’s (DOJ) Antitrust Division, in partnership with the United States Postal Service (USPS), announced the launch of a Whistleblower Rewards Program. This new initiative is designed to...more
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)
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
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
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
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
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 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
Georgia Laboratory Owner Pleads Guilty to Felony Anti-Kickback Statute Violations -
On February 28, the US Department of Justice (DOJ) announced the guilty plea of Andrew Maloney, who, along with his clinical laboratory...more
3/11/2024
/ Anti-Kickback Statute ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Drug Testing ,
False Claims Act (FCA) ,
Federal Food Drug and Cosmetic Act (FFDCA) ,
Fines ,
Fraud ,
Guilty Pleas ,
Healthcare Fraud ,
IRS ,
Medicaid ,
Medicare Fraud ,
Opioid ,
Sentencing ,
Settlement ,
Tax Evasion ,
TRICARE
This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more
1/15/2024
/ Bribery ,
Clawbacks ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Due Diligence ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Instant Messaging Apps ,
Policies and Procedures ,
Political Contributions ,
Remediation ,
Risk Assessment ,
SAP SE ,
Securities and Exchange Commission (SEC) ,
Settlement
Ultragenyx to Pay $6 Million To Settle False Claims Act Case -
Ultragenyx Pharmaceutical Inc. recently agreed to pay $6 million to settle a qui tam action filed under the False Claims Act (FCA).
Ultragenyx manufactures a...more
1/8/2024
/ Anti-Kickback Statute ,
Billing Errors ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Food and Drug Administration (FDA) ,
Fraud ,
Health Care Providers ,
Medicare ,
Popular ,
Qui Tam ,
Settlement
On December 21 President Biden signed the Foreign Extortion Prevention Act (FEPA) as part of the Fiscal Year 2024 National Defense Authorization Act. The legislation addresses a perceived gap in the Foreign Corrupt Practices...more
12/28/2023
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Due Diligence ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
NDAA ,
Policies and Procedures ,
Risk Assessment ,
Securities and Exchange Commission (SEC)
Health Care Network Settles False Claims Act Allegations for $345 Million -
Community Health Network Inc. (CHN) has agreed to pay $345,000,000 to settle allegations that it violated the False Claims Act (FCA) for knowingly...more
12/27/2023
/ Compensation ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
False Billing ,
False Claims Act (FCA) ,
Healthcare ,
Healthcare Fraud ,
Insurance Fraud ,
Medicare ,
Money Laundering ,
OIG ,
Securities Fraud ,
Sentencing ,
Special Purpose Acquisition Companies (SPACs) ,
Wire Fraud
Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance. In the past few months, the DOJ has entered into settlement agreements that...more
11/15/2023
/ Anti-Corruption ,
Clawbacks ,
Compensation ,
Compliance ,
Corporate Misconduct ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
Self-Disclosure Requirements ,
Settlement
On October 4, Deputy Attorney General Lisa O. Monaco addressed the Society of Corporate Compliance and Ethics and announced a new Department-wide Mergers & Acquisition (M&A) Safe Harbor policy. According to the new policy,...more
10/17/2023
/ Acquisitions ,
Anti-Corruption ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Due Diligence ,
Foreign Corrupt Practices Act (FCPA) ,
Mergers ,
Safe Harbors ,
Self-Disclosure Requirements