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Enforcement Actions Third-Party Service Provider Civil Monetary Penalty

Venable LLP

OIG Reminds Us that Flat Fee Business Arrangements Aren’t Immune from AKS Scrutiny

Venable LLP on

On July 1, 2025, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services issued Advisory Opinion No. 25-08, concluding that a medical device manufacturer’s proposed payment to access a...more

WilmerHale

California AG Issues Largest Monetary Penalty in Most Recent CCPA Enforcement Action

WilmerHale on

On July 1, the California Attorney General (CA AG) announced a $1.55 million settlement – the largest penalty issued under the California Consumer Privacy Act (CCPA) to date – with Healthline, an online health and wellness...more

Williams Mullen

DOJ Policy Restores Settlement Agreements Involving Payments to Non-Governmental Third Parties

Williams Mullen on

Settlement agreements regarding payments to non-governmental third parties were sharply curtailed by the Trump administration. A recent DOJ policy and rulemaking restores the authority for DOJ to enter into settlements...more

Bracewell LLP

Who Is Watching The Watchmen?: CFTC Penalizes Registrant For Outsourced IT Security Lapses

Bracewell LLP on

On February 12, 2018, the Commodity Futures Trading Commission (CFTC) settled charges against AMP Global Clearing LLC (AMP), a futures commission merchant (FCM), for the company’s failure to adequately supervise one of its IT...more

Downey Brand LLP

DOJ Issues Policy Memo Limiting the Use of Supplemental Environmental Projects in Federal Settlements

Downey Brand LLP on

On June 7, 2017, the United States Department of Justice (DOJ) issued a policy memorandum dated June 5, 2017 that prohibits the allocation of settlement funds to non-governmental, third-party organizations, as a condition of...more

Foley & Lardner LLP

A Compilation of Non-Enforcement and Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - Mutual Fund Directors Must Be Vigilant in Addressing Risks - In remarks to the Mutual Fund Directors Forum, SEC Chair Mary Jo White outlined some of the risks and challenges that mutual fund...more

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