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Update on Regulatory Compliance in the Global Health Care Industry

A comprehensive understanding of the constantly evolving layers that make up federal anti-corruption statutes, sanctions regulations and export control restrictions is imperative for both the pharmaceutical and health care...more

Enforcement Update – DOJ Raises Focus on Prosecuting Individuals

There has been a change in the US Department of Justice regarding corporate disclosures. The recently updated United States Attorney’s Manual has revised its provisions called the “Principles of Federal Prosecution of...more

Weak Compliance Programs Won’t Protect You from Criminal Misconduct

The Department of Justice’s (DOJ’s) Criminal Division has now hired “Compliance Counsel” but the Department has no plans to move towards making a formal compliance defense available to those charged with regulatory...more

From FCPA to Export Compliance: Avoiding the Slippery Slope to a Compliance Violation

The second half of 2013 saw the continued expansion of FCPA enforcement by the DOJ and the SEC. The decrease in the scope of protections afforded to whistleblowers will lead to an increase in the number of FCPA potential...more

2/28/2014  /  Compliance , Dodd-Frank , DOJ , FCPA , SEC , Whistleblowers

What can you take-away from Total S.A.’s recent FCPA settlement?

I try to avoid talking about Foreign Corrupt Practices Act (FCPA) issues seeing as though it’s quite a popular topic. However, I can’t ignore the vital take-aways from the 10 year FCPA investigation into Total S.A. (Total),...more

7/30/2013  /  Bribery , DOJ , FCPA , Iran , SEC , Settlement

Focus on Health Care Firms in FCPA Investigations

I am seeing a lot of interest from health care clients regarding the Foreign Corrupt Practices Act (FCPA). I usually stay away from this topic because so many others cover it in detail. However, I want to point out that in...more

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