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Investigations Newsletter: Testing Facility Settles $2.5 Million Anti-Kickback Lawsuit

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

Compulsory Corporate Monitorships: Strategies for Success

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

Second Circuit: Whistleblower Must Adequately Allege Willfulness to Assert FCA Claims Based on AKS Violations

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

DOJ Continues Focus on Corporate Crime with New Whistleblower Program

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

Investigations Newsletters: Georgia Laboratory Owner Pleads Guilty to Felony Anti-Kickback Statute Violations

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

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

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

Investigations Newsletter: Ultragenyx to Pay $6 Million To Settle False Claims Act Case

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

What Does the New FEPA Legislation Mean for FCPA and Anti-Corruption Compliance Programs?

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

Investigations Newsletter: Health Care Network Settles False Claims Act Allegations for $345 Million

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

Show Me the Money: Using Compensation Structures to Promote Compliance

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

DOJ Announces New Mergers & Acquisitions Safe Harbor Policy for Voluntary Self-Disclosures

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

Investigations Newsletter: FTX Founder’s Fraud Trial Continues in Manhattan Court

FTX Founder’s Fraud Trial Continues in Manhattan Court - The criminal trial of Sam Bankman-Fried continued this week in Manhattan where the FTX founder faces several charges, including fraud, conspiracy, and money...more

Investigations Newsletter: Former NBA Player Sentenced to 10 Years in Prison for Health Care Fraud

Former NBA Player Sentenced to 10 Years in Prison for Health Care Fraud - Terrence Williams, a former NBA player, was sentenced to 10 years in prison for his participation in a scheme to defraud the NBA’s Health and...more

Investigations Newsletter: Texas Clinical Laboratory and Owner to Pay $5.7 Million to Resolve Outstanding FCA Judgment

Texas Clinical Laboratory and Owner to Pay $5.7 Million to Resolve Outstanding FCA Judgment - Defunct BestCare Laboratory Services LLC and its founder will pay $5.7 million to settle an outstanding 2018 False Claims Act...more

Investigations Newsletter: Surgeon To Pay Up to $43 Million for FCA Fraud

Surgeon To Pay Up to $43 Million for FCA Fraud - A Michigan vascular surgeon, Vasso Godiali, was sentenced to 80 months in prison for defrauding health care programs in connection with his submission of false claims for...more

Investigations Newsletter: Federal Judge Affirms $487 Million Judgment Against Medical Device Distributor for FCA Violations

Federal Judge Affirms $487 Million Judgment Against Medical Device Distributor for FCA Violations - On May 12, 2023, US District Judge Wilhelmina M. Wright of the District of Minnesota affirmed the entry of a $487 million...more

Investigations Newsletter: Supreme Court to Hear US Government in FCA Scienter Oral Argument

Supreme Court to Hear US Government in FCA Scienter Oral Argument - On March 20, 2023, the US Supreme Court agreed to allow the federal government to participate in oral argument in the Supreme Court’s review of the...more

Investigations Newsletter: DOJ Files FCA Complaint Against Major Pharmacy Retailer Based on Alleged Violations of Controlled...

DOJ Files FCA Complaint Against Major Pharmacy Retailer Based on Alleged Violations of Controlled Substances Act - On March 13, 2023, the Department of Justice (DOJ) announced that it filed a complaint in intervention...more

Investigations Newsletter: US Supreme Court to Address FCA's Scienter Requirement in Safeway Case

US Supreme Court to Address FCA’s Scienter Requirement in Safeway Case - The US Supreme Court granted certiorari to resolve a circuit split regarding whether a defendant “knowingly” violates the False Claims Act (FCA) if...more

Investigation Newsletter: Florida Doctor Receives 20-Year Prison Sentence for Substance Abuse Treatment Fraud

Florida Doctor Receives 20-Year Prison Sentence for Substance Abuse Treatment Fraud - Following a guilty plea to conspiracy to commit health care and wire fraud, a Florida doctor was sentenced to 20 years in prison for...more

Investigations Newsletter: Elizabeth Holmes Sentenced to 11 Years in Prison 

Elizabeth Holmes Sentenced to 11 Years in Prison - On November 18, 2022, former Theranos CEO, Elizabeth Holmes, was sentenced to 11 years and three months in prison for defrauding investors regarding Theranos’ blood...more

Investigations Newsletter: DOJ Indicts 47 Individuals in Largest COVID-19 Fraud Scheme To Date

DOJ Indicts 47 Individuals in Largest COVID-19 Fraud Scheme To Date - On September 20, 2022, the US Department of Justice (“DOJ”) announced federal criminal charges against 47 defendants from the nonprofit, Feeding Our...more

Investigations Newsletter: EmpiresX Head Trader Pleads Guilty to $100M Cryptocurrency Investment Fraud Scheme

EmpiresX Head Trader Pleads Guilty to $100M Cryptocurrency Investment Fraud Scheme - On September 8, 2022, the “Head Trader” for EmpiresX, a purported cryptocurrency platform, pled guilty to one count of conspiracy to...more

Investigation Newsletter: Eli Lilly Accused of Defrauding Government in $60 Million Qui Tam Suit

Eli Lilly Accused of Defrauding Government in $60 Million Qui Tam Suit - In a qui tam suit alleging that Eli Lilly and Co. (“Eli Lilly”) violated the False Claims Act, a whistleblower contended that Eli Lilly defrauded...more

Investigations Newsletter: Dozens Charged in $1.2 Billion Nationwide Telemedicine and DME Fraud Scheme

On July 20, 2022, the Justice Department announced that it brought criminal charges against 36 defendants in 13 federal districts across the country, charging more than $1.2 billion in alleged telemedicine, cardiovascular and...more

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