Vince Farhat

Vince Farhat

Holland & Knight LLP

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Latest Publications


DOJ Targets Executives and Individuals in Corporate Investigations

Responding to criticism stemming from a lack of individual prosecutions as a result of the financial crisis, Deputy Attorney General Sally Yates has issued a new guidance memorandum establishing six new steps for federal...more

9/23/2015 - Bylaws Civil Liability Compliance Corporate Fraud Corporate Investigations Criminal Investigations Criminal Prosecution D&O Insurance Disclosure Requirements DOJ Enforcement Actions Ethics False Claims Act (FCA) Federal Prosecutors Individual Accountability Internal Investigations Professional Misconduct White Collar Crimes

Boeing Kickback Case Underscores Critical Importance of Compliance Programs - Government Contractors Must Be Proactive in...

In the words of F. Scott Fitzgerald, "Show me a hero and I'll write you a tragedy." When the hero of the day is a company's compliance program, it's almost a surefire bet that that a tragedy is being written. But at the same...more

4/29/2015 - Boeing Chief Compliance Officers Compliance Defense Sector Federal Contractors Kickbacks Risk Mitigation

U.S. Sentencing Commission Approves Major Changes to Fraud Guidelines - The Updates Could Significantly Affect White Collar...

On April 9, 2015, the United States Sentencing Commission voted to approve changes to §2B1.1 of the sentencing guidelines. The changes will take effect on Nov. 1, 2015, unless Congress objects. If they go into effect, these...more

4/17/2015 - Criminal Prosecution Federal Sentencing Guidelines Fraud Intent Proposed Amendments Sentencing Enhancements White Collar Crimes

Attorney Withdrawal: Protect the Client, Obey the Court or Go to Jail? - California Formal Op. No. 2015-192 Addresses the Ethical...

In Formal Opinion No. 2015-192, the California State Bar Standing Committee on Professional Responsibility and Conduct addressed the difficult choices faced by lawyers who are ethically required to seek leave to withdraw from...more

2/20/2015 - Attorney-Client Privilege Confidential Information Ethics Legal Ethics

Ethical Issues For White Collar Defense And Investigations Lawyers - Part 1 of 3: Joint Defense Agreements

Recent corporate scandals have made effective and honest corporate governance the chief priority for every company. Proactive and incisive white collar defense counsel in this area is a must. Reacting swiftly to serious...more

12/18/2014 - Corporate Governance Criminal Prosecution Defense Strategies Ethics Government Investigations

DOJ Shifts Stance on False Statements Prosecutions - A Change That Could Have a Major Impact on Future White Collar...

The U.S. Department of Justice (DOJ) recently adopted a more defense-friendly position on criminal prosecutions under a commonly used federal charging statute, Section 1001. This statute makes it a crime to "knowingly and...more

5/30/2014 - Criminal Prosecution DOJ Enforcement Enforcement Actions False Statements Fraud Investigations White Collar Crimes

Proposed Anti-Human Trafficking Rule Could Significantly Affect Contractor Compliance Programs

U.S. government contractors and subcontractors may need to comply with two new federal procurement rules proposed by the Obama administration to prevent the use of forced labor. Affected companies should review and...more

1/8/2014 - Forced Labor Human Rights Human Trafficking NDAA Supply Chain Transparency

Amendments to California False Claims Act Expand Potential Exposure to Government Investigations and Litigation

On September 27, 2012, Governor Jerry Brown signed into law Assembly Bill 2492 (AB 2492), which amends the California False Claims Act (CFCA). These amendments closely align the CFCA with the federal False Claims Act (FFCA)....more

1/9/2013 - Attorney Generals Compliance False Claims Act (FCA) FERA Whistleblowers

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