The DOJ Fraud Section’s “Evaluation of Corporate Compliance Programs” puts chief compliance officers on notice about how the adequacy of their companies’ compliance programs is evaluated by prosecutors....more
The US Department of Justice has announced the creation of a one-year pilot program intended to encourage companies to self-report bribery violations and provide extensive cooperation in exchange for reduced penalties,...more
DOJ announces tough new approach to the investigation and prosecution of corporate officers and employees.
On September 9, in a major change to its approach to the investigation of alleged corporate crime, the US...more
9/15/2015
/ Cooperation ,
Corporate Officers ,
Corporate Veil ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Guidance ,
Government Investigations ,
Individual Accountability ,
Internal Investigations ,
Investigations ,
Law Enforcement ,
Non-Prosecution Agreements ,
Personal Liability ,
Professional Misconduct ,
Voluntary Disclosure ,
White Collar Crimes
Court rules that the US Department of Justice cannot expand the FCPA’s reach simply by charging non-resident foreign nationals with conspiracy....more
The court’s interpretation complicates the already difficult task providers face in having sufficient time to assess and quantify potential overpayments.
An August 3 decision in United States v. Continuum Health Partners...more
8/6/2015
/ Affordable Care Act ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Health Care Providers ,
Healthcare ,
Hospitals ,
Medicaid ,
Medicare ,
Overpayment ,
Qui Tam ,
Relators
Revisions bring DOJ and SEC guidance in line with FCPA statutory language.
In June, the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) quietly revised its manual, A Resource Guide to the U.S....more
8/6/2015
/ Accounting Standards ,
Compliance ,
Criminal Penalties ,
Department of Justice (DOJ) ,
Enforcement ,
FCPA Resource Guide ,
Foreign Corrupt Practices Act (FCPA) ,
Good Faith ,
Internal Controls ,
Joint Venture ,
Securities and Exchange Commission (SEC) ,
Transparency
Federal appeals court provides a two-step “control” and “function” analysis for determining whether an entity qualifies as an “instrumentality” under the Foreign Corrupt Practices Act.
On May 16, the U.S. Court of...more