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Christopher R. Hall

Christopher R. Hall

Saul Ewing LLP


Latest Publications

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State v. Brown Affords Managers in the Mortgage Processing Industry a Cautionary Tale

In Brief: - Significant jail time can result from overseeing and directing unauthorized robo-signing activities. - Victims of unauthorized robo-signing include residential mortgage servicers, in addition to...more

5/24/2013 - Attorney Generals Investigations Mortgages Robo-Signing

White Collar Watch - May 2013

In This Issue: - SEC Charges Municipal Bond Issuer with Securities Fraud for Misleading Statements on Issuer’s Website - State v. Brown Affords Managers in the Mortgage Processing Industry a Cautionary Tale -...more

5/24/2013

Second Highest Penalty in FCPA History Comes with a Caution from the Bench about the Limits of the Act’s Jurisdiction

In Brief - The Foreign Corrupt Practices Act covers a nearly boundless range of business conduct by issuers and their agents in an ever more global world. Yet the contrast in sentences handed down in two recent FCPA...more

5/24/2013

Casting a Smaller Net: Seventh Circuit Requires "Net Trebling" Under FCA – Potentially Impacting Settlement Dynamics for all...

The Seventh Circuit recently ruled that under the False Claims Act (“FCA”) treble damages should be calculated by the net amount of loss suffered by the government (after appropriate setoffs or credits are deducted) rather...more

4/24/2013 - False Claims Act Misrepresentation Mortgages Net Trebling Settlement Treble Damages

Doing Time: A Requirement for White Collar Crime?

A recent decision from the Eleventh Circuit indicates that deterring future white collar crime is a substantial factor in shaping appellate court rulings relating to appropriate sentences for fraud, particularly when a...more

4/24/2013 - Abuse of Discretion Federal Sentencing Guidelines Fraud Sentencing Venue White Collar Crimes

White Collar Watch - April 2013

In This Issue: - Third Circuit Panel Liberalizes “Protected Activity” Immunity for Employees Claiming Whistleblower Status - Doing Time: A Requirement for White Collar Crime? - Casting a Smaller Net:...more

4/23/2013 - CMS Continuing Medical Education Financial Conduct Authority Fraud GPOs Protected Activity Publicly-Traded Companies Sarbanes-Oxley Settlement Shareholders Sunshine Act Transparency Whistleblower Protection Policies Whistleblowers White Collar Crimes

Supreme Court Holds SEC to Five-Year Statute of Limitations for Civil Enforcement Actions; Decision May Extend to Other Federal...

The Supreme Court recently rebuffed an attempt by the U.S. Securities and Exchange Commission (“SEC”) to gain more time to file actions to enforce civil penalties by invoking the “discovery rule.” In the case of Gabelli vs....more

3/25/2013 - Discovery Rule Gabelli v SEC SCOTUS SEC Statute of Limitations

The D.C. Circuit Expands the Scope of Honest-Services Fraud and Illegal-Gratuities Prosecutions in Ring v. United States

The U.S. Court of Appeals for the D.C. Circuit in United States v. Ring recently upheld a conviction under the public sector “honest-services” fraud statute and the “illegal-gratuities” statute. Notably, the court: (1)...more

3/25/2013 - Compliance DOJ Honest Services Fraud Illegal Gratuities Jack Abramoff Lobbyists Ring v US

Court Upholds Executive’s Conviction Stemming from Off-Label Drug Promotion

The U.S. Court of Appeals for the Ninth Circuit has upheld the wire fraud and misbranding convictions and sentence of InterMune Inc. founder W. Scott Harkonen. United States v. Harkonen, No. 11-10209 (9th Cir. March 4, 2013)....more

3/25/2013 - Commercial Speech FDCA InterMune Labeling Marketing Misbranding Off-Label Promotion Pharmaceutical Wire Fraud

White Collar Watch - March 2013

In This Issue: - Eleventh Circuit Holds that Production of Foreign Bank Account Records May be Compelled in Criminal Investigation Under Required Records Exception to Fifth Amendment Privilege - Supreme Court...more

3/22/2013 - Discovery DOJ Fifth Amendment Foreign Financial Accounts Honest Services Fraud Illegal Gratuities Motion to Compel Off-Label Promotion Records Exception SCOTUS SEC Statute of Limitations

White Collar Watch - February 2013

In This Issue: - New HIPAA “Megarule” Broadens Enforcement - Government Declines to Seek Rehearing of Landmark Off-Label Speech Decision - Seizure of Rothstein Ponzi Assets Highlights Tension Between...more

2/22/2013 - Forfeiture Statutes Free Speech HIPAA Market Recovery Mary Jo White Off-Label Use Petition For Rehearing Ponzi Scheme White Collar Crimes

Death and Taxes? Recent Supreme Court Arguments in Gabelli v. SEC Concerning a General Statute of Limitations for Civil Fines May...

On January 8, the Supreme Court of the United States heard oral arguments in Gabelli v. S.E.C., 133 S. Ct. 97 (2012) on the question: By when must the government initiate an action to enforce a civil fine, penalty, or...more

1/25/2013 - Civil Monetary Penalty Discovery Rule Enforcement Fines Forfeiture Fraud Gabelli v SEC IRS SCOTUS SEC Securities Fraud Statute of Limitations White Collar Crimes

White Collar Watch - January 2013

In This Issue: - Death and Taxes? Recent Supreme Court Arguments in Gabelli v. SEC Concerning a General Statute of Limitations for Civil Fines May Also Affect How Long the IRS Has to Assess Penalties - Avoiding...more

1/23/2013 - Attorney-Client Privilege Discovery Rule Environmental Crimes EPA Fines Fraud Gabelli v SEC IRS Payroll Taxes Penalties Plea Negotiations Responsible Person Liability SCOTUS SEC Selective Waivers Statute of Limitations White Collar Crimes

Second Circuit Jettisons Criminal Conviction for Pharma Rep Convicted for Off-Label Promotion

On December 3, 2012, the United States Court of Appeals for the Second Circuit overturned the conviction of a pharmaceutical sales representative convicted for misbranding in violation of the federal Food, Drug and Cosmetic...more

12/20/2012 - FDCA First Amendment Misbranding Off-Label Promotion Pharmaceutical

The SEC’s Annual Report on the Dodd-Frank Whistleblower Program: Statistics Suggest Best Practices for an Effective Compliance and...

The Securities and Exchange Commission’s Annual Report on the Dodd-Frank Whistleblower Program, released November 2012, provides the first complete year of data on the activities of the Office of the Whistleblower (“OWB”)...more

12/20/2012 - Compliance Dodd-Frank Ethics Sanctions SEC Whistleblowers

White Collar Watch - November 2012

In This issue: - DOJ and SEC Issue Long-Awaited Guidance on the FCPA - Recent Sentencings of Executives Serve as Reminder of Risks of Responsible Corporate Officer Prosecutions; Risks Grow for Medical Device...more

11/21/2012 - Compliance DOJ FCPA FCPA Resource Guide SEC

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