Earlier this summer, the Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs guidance. As the recent updates make clear, one of the hallmarks of an effective corporate compliance program is the...more
Earlier this month, the Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs guidance. The updated guidance does not suggest that corporations will be rewarded for deemphasizing or not...more
In Part 3 of this series of Client Alerts, we conclude by offering practical advice for reporting companies about how to assess and respond to certain risks when considering their disclosure obligations....more
On November 5, 2019, Antitrust Division Assistant Attorney General Makan Delrahim announced the creation of a joint law enforcement task force to combat antitrust crimes and other fraudulent schemes impacting government...more
For years the Antitrust Division of the Department of Justice resisted, in contrast to the Criminal Division, considering and awarding credit for companies' "robust" compliance programs....more
Recent Department of Justice (DOJ) pronouncements, as well as older Federal Acquisition Regulation (FAR) requirements, present both duties and opportunities for government contractors to investigate and report fraudulent or...more
The U.S. Justice Department has updated its "Evaluation of Corporate Compliance Programs," a guidance document detailing topics and questions prosecutors should weigh when determining whether a company has demonstrated...more
5/29/2019
/ Ambulatory Surgery Centers ,
Board of Directors ,
Compliance ,
Corporate Executives ,
Corporate Misconduct ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Disciplinary Proceedings ,
Ethics ,
Government Investigations ,
Health Care Providers ,
Hospitals ,
Internal Audit Functions ,
Internal Investigations ,
Long Term Care Facilities ,
Nursing Homes ,
Physicians ,
Tone At The Top
On May 9, 2018, Deputy Attorney General Rod Rosenstein announced a new Department of Justice policy that "encourages coordination among Department components and other enforcement agencies when imposing multiple penalties" in...more
In early April 2018, the Antitrust Division of the U.S. Department of Justice (DOJ) settled allegations against Knorr-Bremse AG and Wabtec, manufacturers of rail equipment. The claims involved a "no-poach" agreement barring...more
On October 20, 2016, the Federal Trade Commission (FTC) and the Department of Justice Antitrust Division (DOJ) issued a joint Antitrust Guidance for Human Resources Professionals to address antitrust issues associated with...more
Under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, the Department of Justice (DOJ), Federal Trade Commission (FTC) and other agencies have raised the maximum civil penalties (CMPs) for legal...more