Despite the sobering news reports on the global spread of COVID-19, companies are continuing to try to conduct operations as (relatively) normally as possible. International business is particularly affected given the...more
• A payment to a government official can take many forms.
• The SEC charges bank for books and records violation even absent a bribery charge.
• Industry-wide enforcement is a continuing tactic for U.S....more
10/24/2019
/ Accounting Controls ,
Banking Sector ,
Banks ,
Books & Records ,
Bribery ,
Enforcement Actions ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Government Officials ,
Hiring & Firing ,
Internal Controls ,
Internships ,
Quid Pro Quo ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements
On March 29, 2019, the U.S. Department of Justice (DOJ) announced it had initiated the first-ever criminal prosecution of individual business executives for alleged failure to timely disclose product safety issues to federal...more
• The World Bank aggressively pursues sanctions against entities and individuals for misconduct in connection with Bank-funded projects
• Sanctions can lead to cross-debarment by other multilateral development banks and...more
In a remarkable move, the Department of Justice (DOJ) recently sought dismissal of 11 False Claims Act (FCA) cases, each of which assert that patient assistance services supplied by pharmaceutical manufacturers constitute...more
On November 30, 2018, the Solicitor General of the United States filed an amicus curiae brief in the closely watched False Claims Act (FCA) lawsuit, Gilead Sciences Inc. v. U.S. ex rel. Campie. In what appears to be an...more
12/6/2018
/ Amicus Briefs ,
Department of Justice (DOJ) ,
Discovery ,
False Claims Act (FCA) ,
Food and Drug Administration (FDA) ,
Gilead Sciences Inc v United States ex rel Campie ,
Manufacturers ,
Materiality ,
Misrepresentation ,
Motion to Dismiss ,
Petition for Writ of Certiorari ,
Pharmaceutical Industry ,
Prescription Drugs ,
Qui Tam ,
Reimbursements ,
Relators ,
Remand ,
Solicitor General
In a much-anticipated decision, the U.S. Court of Appeals for the Second Circuit ruled Friday that the Foreign Corrupt Practices Act (FCPA) did not apply to a foreign national acting outside the United States without direct...more
8/28/2018
/ Appeals ,
Bribery ,
Criminal Conspiracy ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Dismissals ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Interlocutory Appeals ,
Jurisdiction ,
Reversal