The U.S. Department of Justice is recasting the False Claims Act as a civil rights enforcement tool—putting federal fund recipients on notice that false compliance certifications may now trigger FCA liability....more
DOJ settlement signals need for enhanced False Claims Act scrutiny.
Private funds continue to face heightened secondary liability risks arising from their portfolio investments....more
10/3/2019
/ Compliance ,
D&O Insurance ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Contractors ,
Independent Directors ,
Internal Controls ,
Kickbacks ,
Pensions ,
Pharmacies ,
Portfolio Companies ,
Private Equity Firms ,
Private Investment Funds ,
Risk Management ,
Settlement ,
Strategic Enforcement Plan ,
Vicarious Liability
Earlier this week, the U.S. Supreme Court resolved a circuit split among the Tenth and Eleventh Circuit Courts of Appeals by holding that because disgorgement in a Securities and Exchange Commission (SEC) enforcement action...more
6/9/2017
/ Disgorgement ,
Enforcement Actions ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Investment Management ,
Kokesh v SEC ,
Misappropriation ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Statute of Limitations ,
White Collar Crimes
On September 9, 2015, Deputy Attorney General Sally Quillian Yates introduced a new policy aimed at aggressively prosecuting individuals for white-collar crimes. A product of a DOJ working group that started under former...more