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On July 2, 2025, the U.S. Court of Appeals for the Second Circuit ruled in United States v. Lopez that foreign commercial bribery schemes fall within the ambit of the honest services wire fraud statute, 18 U.S.C. §...more
The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
In the legal and compliance space, it is easy to ignore significant incidents involving domestic bribery and fraud. We are fixated on FCPA foreign bribery cases, as well as domestic healthcare fraud, anti-kickback violations...more
Mark Schena, the President of Arrayit Corporation, has been found guilty by a jury for violations of the Eliminating Kickbacks in Recovery Act (EKRA), healthcare fraud, wire fraud, and securities fraud....more
If our most recent Fraud Week post (NY Chiropractor Billed for Non-Existent Acupuncture Services) didn’t already drive home the point, it is worth emphasizing that billing insurers for items or services that weren’t actually...more
The Justice Department announced the arrest and indictment of Charles Hunter Hobson for violating the FCPA, money laundering and receiving kickbacks arising from a bribery scheme to pay government officials in Egypt in...more
Credit Suisse Group AG (“Credit Suisse”), a global financial institution, and its London-based European subsidiary, Credit Suisse Securities (Europe) Limited (“CSSEL”) resolved a wide-ranging bribery and fraud scheme...more
Although courts have reined in the application of the Foreign Corrupt Practices Act (FCPA) anti-bribery provisions in the past two years, the US Department of Justice (DOJ) shows no sign of scaling back its global...more
FCPA cases can arise in un usual situations. DOJ has focused two separate prosecutions on bribery and fraud involving adoptions from Uganda and Poland. At the heart, the defendants bribed Ugandan and Polish authorities to...more
To our bad guys, 2019 was a year flush with hope and opportunity; it ended with recidivism, more misery from Venezuela, a charlatan, an Okie who pulled a multi-million dollar fast-one on Chesapeake and, as in years past, a...more
The Justice Department won another FCPA trial. After a three-week trial, Mark Lambert of Mount Airy, Maryland, was found guilty of four counts of violating the FCPA, two counts of wire fraud and one count of conspiracy to...more
Last Friday, the Department of Justice (DOJ) secured another trial court conviction in a Foreign Corrupt Practices Act (FCPA) prosecution involving an individual. Following on the heels of the Hoskins guilty verdict, it...more
This week I have been considering the guilty pleas of the former Unaoil Chief Executive Officer (CEO), Cyrus Ahsani, and former Chief Operations Officer (COO), Saman Ahsani, as was laid out in their Information. Most...more
The Justice Department’s sprawling and successful prosecution of bribery and money laundering surrounding PDVSA, Venezuela’s state-owned energy company, shows no signs of letting up. ...more
ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more
ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more
ANTICORRUPTION DEVELOPMENTS - DOJ Extends FCPA Corporate Enforcement Policy to Misconduct in Mergers and Acquisitions - On July 25, 2018, in a speech to the Ninth Global Forum on Anti-Corruption Compliance in High Risk...more
Last week, the Justice Department announced its first FCPA enforcement action in 2018 – a follow-on settlement from prior FCPA enforcement actions centering on a bribery scheme involving a Russian government official from a...more
Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more
Today, October 2, is the first Friday in October so I begin my annual month of Friday HorrorFest Film highlights. This year I wanted to highlight the films of one of the great unknowns of horror films, Val Lewton. Lewton, a...more
Four SEC Commissioners addressed the annual SEC Speaks Conference, reviewing recent agency initiatives and tracing potential paths for the future. The SEC also brought another FCPA action, a misappropriation case and an...more