News & Analysis as of

Civil Monetary Penalty Enforcement

Arnall Golden Gregory LLP

“Longstanding and Clear”: OIG Continues Characteristic Close Scrutiny of Below-Market Benefits to Referral Sources

The United States Department of Health and Human Services, Office of Inspector General (“OIG”) recently released two unfavorable advisory opinions, OIG Advisory Opinion No. 25-04 and -08 (the “Opinions”) to medical device...more

Parker Poe Adams & Bernstein LLP

U.S. Labor Department Will Not Seek Pre-Suit FLSA Liquidated Damages

Under the Fair Labor Standards Act, violations of overtime or minimum wage requirements can result in assessment of liquidated damages equal to the amount of unpaid wages. ...more

Nelson Mullins Riley & Scarborough LLP

“Free your mind!” — Understanding the CFTC’s New Mitigation Credit Matrix

The Commodity Futures Trading Commission (CFTC) recently issued a significant Enforcement Advisory detailing how companies and individuals can earn Mitigation Credit....more

Morrison & Foerster LLP

CPSC’s 2024 Year in Review

In recent years, the Consumer Product Safety Commission (CPSC) has increased pressure on consumer product companies through various enforcement mechanisms. The increase in the frequency and amount of civil penalties sought by...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Section 311/Clean Water Act Enforcement: U.S. Environmental Protection Agency and Laconia, New Hampshire Car Care Center Enter...

Section 311/Clean Water Act Enforcement: U.S. Environmental Protection Agency and Laconia, New Hampshire Car Care Center Enter into Expedited Settlement Agreement - The United States Environmental Protection Agency (“EPA”)...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Buffalo, New York Diagnostics Facility Enter into Consent...

The United States Environmental Protection Agency (“EPA”) in IMMCO Diagnostics (“ID”) entered into an October 3 expedited settlement agreement (“ESA”) addressing an alleged violation of the Resource Conservation Recovery Act...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Tennessee Department of Environment and Conservation Proposed Director's Order and Assessment...

The Tennessee Department of Environment and Conservation (“TDEC”) issued a January 17th Proposed Director’s Order and Assessment (“Order”) to Sherwin-Williams Company (“Sherwin-Williams”) addressing alleged violations of the...more

McGlinchey Stafford

Stericycle Agrees to Pay $9.5 Million Civil Penalty for RCRA Violations

McGlinchey Stafford on

On January 17, 2025, the Environmental Protection Agency (EPA) and the Department of Justice (DOJ) announced a $9.5 million settlement with Stericycle, Inc. for Hazardous Waste Management Violations. The settlement resolves...more

Gardner Law

Sunshine Act Compliance: How to Take Action to Meet Reporting Requirements and Avoid Costly Penalties

Gardner Law on

The clock is ticking for medical device and pharmaceutical companies to fulfill their obligations under the Physician Payments Sunshine Act (the "Sunshine Act"). With the reporting deadline of March 31 looming and CMS...more

Mintz - Health Care Viewpoints

EnforceMintz — Telemedicine Enforcement: Trends in 2024 Suggest More Sophisticated Enforcement to Come in 2025

The Department of Justice (DOJ) and the Office of the Inspector General for the Department of Health and Human Services (OIG) have historically focused their virtual health care enforcement efforts on “traditional”...more

Hinch Newman LLP

Business Coaching Program Alert: FTC Proposes Changes to Biz Opp Rule to Deter Deceptive Earnings Claims – Republican...

Hinch Newman LLP on

On January 13, 2025, the Federal Trade Commission announced that it is seeking comment on proposed changes to the Business Opportunity Rule and a proposed new Earnings Claim Rule. According to the FTC, the two, taken...more

Foley & Lardner LLP

NHTSA Adopts Final Rule to Formalize its Whistleblower Program under the Motor Vehicle Safety Whistleblower Act

Foley & Lardner LLP on

On December 17, 2024, the National Highway Traffic Safety Administration (“NHTSA” or “Agency”) adopted a final rule to formalize its whistleblower program under the Motor Vehicle Safety Whistleblower Act (Whistleblower Act). ...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Louisiana Department of Environmental Quality and Moss Bluff Compressor Station Operator Enter into Settlement...

The Louisiana Department of Environmental Quality (“LDEQ”) and Cameron Interstate Pipeline, LLC (“Cameron”) entered into a settlement agreement (“SA”) addressing violations of the Louisiana Air regulations....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Wastewater Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and City of Jasper Enter...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“DEQ”) and City of Jasper, Arkansas entered into a December 4th Consent Administrative Order (“CAO”) addressing alleged violations of a...more

Pillsbury Winthrop Shaw Pittman LLP

Journey's End? Fifth Circuit Issues Splintered Decision in Important Clean Air Act Citizen Suit Case

The nine judges that finally coalesced over the decision of affirmance voted for two inconsistent judgments and provided no explanation for this result. The judges held that, under Laidlaw, civil penalties which must be...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Storage Tank Enforcement: Tennessee Department of Environment and Conservation Proposed Order Addressing Williamson County...

The Tennessee Department of Environment and Conservation (“TDEC”) issued a Proposed Order and Assessment (“Order”) for alleged violations of the Tennessee Petroleum Underground Storage Tank Act and relevant rules. See Case...more

Vinson & Elkins LLP

FERC Enforcement Uses Duty of Candor Rule to Impose Penalties on PJM Utility for Allegations Related to Transmission Planning...

Vinson & Elkins LLP on

The Federal Energy Regulatory Commission’s (“FERC” or “Commission”) Office of Enforcement (“Enforcement”) continues to focus on enforcing its duty of candor rules, with a recent action resulting in a $6.6 million civil...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Costa Mesa, California Automatic Control Valve Manufacturer...

The United States Environmental Protection Agency (“EPA”) and Griswold Industries (“GI”) entered into a January 3rd Expedited Settlement Agreement (“ESA”) addressing alleged violations of the Resource Conservation and...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Solid Waste Enforcement: Alabama Department of Environmental Management and Selma Construction and Debris Landfill Enter into...

The Alabama Department of Environmental Management (“ADEM”) and City of Selma entered into a December 11th Special Order by Consent (“Order”) addressing alleged violations of a Solid Waste Disposal Permit. See Order No....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Wastewater Enforcement: Mississippi Commission on Environmental Quality and Heidelberg Petroleum Refinery Enter into Agreed Order

The Mississippi Commission on Environmental Quality (“MCEQ”) and Hunt Southland Refining Company LLC (“Hunt”) entered into a November 18th Agreed Order (“AO”) addressing alleged violations of a Clean Water Act National...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Tennessee Department of Environment and Conservation Proposed Order and Assessment Addressing Shelby...

The Tennessee Department of Environment and Conservation (“TDEC”) issued on November 15th a Proposed Director’s Order and Assessment (“OA”) to Tradebe Treatment and Recycling of Tennessee, LLC (“TTRT”) addressing alleged...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Wastewater Enforcement: U.S. Environmental Protection Agency and Monroe, Michigan Coal-Fired Powerplant Enter into Consent...

The United States Environmental Protection Agency (“EPA”) and DTE Electric Company (“DTE”) entered into a Consent Agreement and Final Order (“CAFO”) addressing alleged violations of Clean Water Act National Pollutant...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Wastewater Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and City of Glenwood...

Wastewater Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and City of Glenwood Enter Into Consent Administrative Order - The Arkansas Department of Energy and Environment –...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Tennessee Department of Environment and Conservation Proposed Order Addressing Dayton Specialty...

The Tennessee Department of Environment and Conservation (“TDEC”) issued a December 16th Proposed Order and Assessment (“Order”) to Cymer-Dayton, LLC (“CD”). See Case No. HWM 24-0022. The Order provides that CD conducts...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Alabama Department of Environmental Management and Mobile Sawmill Facility Enter into Consent Order

The Alabama Department of Environmental Management (“ADEM”) and Scotch and Gulf Lumber, LLC (“Scotch”) entered into a December 11th Consent Order (“CO”) addressing an alleged violation of a Clean Air Act Title V Major Source...more

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