Michael D. Ricciuti

Michael D. Ricciuti

K&L Gates LLP

Contact  |  View Bio  |  RSS

Latest Publications


“Take Me Out to the Ballgame?” Asked the Inspector: Saying “Yes” May Now Be a Federal Crime

Imagine this hypothetical: A local fire marshal says to Mary Jones, who runs the residence halls at a major university, “It must be nice having seats at the Saturday football games.” Mary gets the message and thinks that if...more

5/13/2016 - Bribery Corruption Extortion Hobbs Act Ocasio v United States Public Officials SCOTUS

Are Your Company’s Legal, Due-Diligence, De-risking, or Compliance Obligations Impacted by the “Panama Papers”?

In an unprecedented event earlier this week, 11.5 million files from the Panamanian law firm Mossack Fonseca were allegedly leaked. Assuming they are genuine, as appears to be the case, these “Panama Papers” offer a...more

4/12/2016 - Anti-Corruption Bribery BSA/AML Criminal Penalties DOJ Due Diligence Enforcement Actions FCPA FinCEN Money Laundering Panama Papers Risk Mitigation SEC Shell Corporations Young Lawyers

Pharmaceutical Diversion – Risks and Steps to Address a Major DEA Focus

The opioid crisis, an ever-increasing focus of the Obama administration and 2016 Presidential Primary field, has highlighted the efforts of the Drug Enforcement Administration (DEA) and the Department of Justice (DOJ) to...more

3/23/2016 - Controlled Substances Act DEA DOJ Drug & Alcohol Abuse OxyContin Pharmaceutical Industry Pharmacies Prescription Drugs

DOJ Sharpens Focus on Corporate Compliance in Deciding Whether to Prosecute Companies

One of the factors that the U.S. Department of Justice (DOJ) considers in deciding whether to bring charges against a corporation is the existence and effectiveness of the corporation’s pre-existing compliance program. On...more

11/5/2015 - Anti-Bribery Anti-Corruption Banking Sector Banks Bribery Compliance Corporate Counsel Corporate Fraud Corruption DOJ Financial Institutions Government Investigations White Collar Crimes

New DOJ Guidance Sharpens the Focus on Prosecuting and Suing Individuals in Corporate Criminal Investigations

On September 9, 2015, the U.S. Department of Justice (“DOJ” or the “Department”) issued a memorandum to its staff revising the principles guiding criminal and, indeed, civil enforcement in corporate criminal investigations...more

9/11/2015 - Criminal Investigations DOJ Enforcement Actions FDA FDCA Indictments White Collar Crimes Willful Misconduct

Corporate Responses to Investigative Requests by the Federal Government

In light of these new realities corporations face, the first step a company should take is to establish internal guidelines addressing interaction with government agents. Companies should have a response policy in place and...more

9/4/2014 - Best Management Practices Government Investigations Investigations Policies and Procedures

Office of Management and Budget Releases New “Omni-Circular” Uniform Administrative Requirements, Cost Principles, and Audit...

On December 26, 2013, the Office of Management and Budget (“OMB”) released a comprehensive guidance that makes changes to the fragmented existing guidance on Administrative Requirements, Cost Principles, and Audit...more

3/19/2014 - Audits Federal Grants OMB Presidential Directives

Enhanced Protections for Federal-Employee Whistleblowers: Sign of Things to Come?

Whistleblowers who work for the federal government recently received greater protection under federal law. These additional protections are significant and close prior gaps in the protections afforded by previous statutes and...more

1/11/2013 - Garcetti Whistleblower Protection Enhancement Act Whistleblower Protection Policies Whistleblowers

Off-Label Marketing Questioned as a Viable Criminal Theory – But Stay Tuned

On December 3, 2012, a divided Second Circuit held in United States v. Caronia (“Caronia”) that the misbranding provisions of the Federal Food, Drug, and Cosmetic Act (“FDCA”) do not criminalize “the truthful off-label...more

12/17/2012 - FDA FDCA First Amendment Marketing Misbranding Off-Label Promotion Off-Label Use Pharmaceutical Industry

9 Results
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.