Creating an Integrated Due Diligence System - Screening to Audits
A Moment of Simple Justice - Revenge Porn
Third Party Due Diligence When is Enough, Enough?
An FCPA Review: A Look Back at 2013 and Trends for 2014
Anti Kickback and Stark Law Enforcement and Compliance Issues
Conducting Interviews in an Internal Investigation 2 13 14, 9 03 AM
A Moment of Simple Justice: Legal Weed
Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM
Internal Investigations: Soup to Nuts (March 13, 2014)
How Can You Better Protect Yourself with the Escalating Trend of FCPA Enforcement?
The Role of a Chief Compliance Officer: Navigating the Compliance Landscape (March 18, 2014)
Keeping Your Due Diligence System Manageable March 31, 2014
Tailoring Your Anti Corruption Program to a Risk Assessment
Managing Your Anti Corruption Policies and Procedures
Designing Cost Effective Risk Assessment Programs May 21, 2014
Managing Your Internal Investigation Program June 3 2014
AML BSA and Sanctions Compliance Part II of II June 24, 2014
AML BSA and Sanctions Compliance I of II June 10 2014
Are Criminal Laws the Right Response to Revenge Porn?
Blecker: GM Recalls Show Need for Harsher Penalties for "Red Collar" Criminals
When a liquor licensee’s former manager is convicted of conspiring to violate the federal Money Laundering Act, can the licensee be summarily stripped of its liquor license, based upon the criminal trial transcript, a...more
The Illinois Supreme Court appeared skeptical of a due process challenge to revocation of a liquor license during the recent oral argument in WISAM 1, d/b/a Sheridan Liquors v. Illinois Liquor Control Commission. ...more
The U.S. Supreme Court's recent term included decisions in several cases with implications on states and states' rights. This presentation included the court's review and opinions handed down for the following cases.
The Alabama Firearms Act of 2013 was signed by Gov. Bentley in May, 2013, thus the effective date should be (at the latest) 08/01/2013.
This long overdue law changed Alabama's system of issuing concealed carry weapon's...more
California attorney Joseph Cavallo was convicted of violating Title 10, CCR section 2071, "recommendation of attorney by bail licensee". The authority to prosecute violations of the bail licensing regulations lies with the...more
In the last post, I addressed the latest events in the case of Michael Misick, former Premier of Turks and Caicos Islands (TCI). Today's post is a continuation of that discussion and an update of a related post from earlier...more
LAW AND GOVERNANCE IN THE FACE OF PUBLIC PRESSURE: A perspective in the backdrop of public outrage over the New Delhi gang rape incident
The paper examines the possible consequences of an executive under public pressure to...more
The Court of Appeals for the Second Circuit sent shockwaves through the pharmaceutical industry with its decision in United States v. Caronia. Alfred Caronia was a pharmaceutical sales representative convicted of a...more
Last week a federal appeals court made a ruling that chips away at a fundamental aspect of the FDA's gatekeeping function with new drugs. The court tossed a conviction of a drug sales representative who was promoting drugs...more
On December 3, 2012, the United States Court of Appeals for the Second Circuit issued an opinion that stands to transform the regulatory landscape in which pharmaceutical and medical device companies operate. In recent...more
In a significant blow to the U.S. government’s enforcement efforts against the pharmaceutical industry, a panel of the Second Circuit overturned the conviction of a pharmaceutical sales representative for conspiracy to...more
A recent decision by the U.S. Court of Appeals for the Second Circuit may significantly curtail enforcement efforts relating to the so-called “off-label” use of drugs approved by the Food and Drug Administration for specific...more
In a much-anticipated opinion, the U.S. Court of Appeals for the Second Circuit vacated and remanded the conviction of Alfred Caronia, a former pharmaceutical sales representative convicted of conspiring to introduce a...more
On October 31, 2012, the Crown filed a Notice of Appeal with the Federal Court of Appeal against the judgment of the Tax Court of Canada in Julie Guindon v. The Queen (2012 TCC 287). In that decision, the Tax Court held that...more
Below is a complete text-version of the attached -- Mass. Treasurer Steven Grossman's Letter to Sen. Reid and Sen. Kyl objecting to the Draft iGaming Prohibition Bill expected to be dropped during the Lame Duck session of...more
Reid-Kyl Draft iPoker and iGaming Prohibition Bill Leaked -- "Internet Gambling Prohibition, Poker Consumer Protection, and Strengthening UIGEA Act of 2012"
A copy of the Kyl-Reid draft bill on Internet poker enabling...more
In what is certain to be the first step in a very important precedent, the Tax Court of Canada held on October 2, 2012 that the advisor penalties created under section 163.2 of the Income Tax Act constitute criminal offences...more
The Interstate Agreement on Detainers, a compact authorized by federal statute, provides a simple procedure for transferring custody of prisoners between states. Because the federal government annually seeks to prosecute...more
EXECUTIVE SUMMARY of the OIG Report:
During law enforcement operations, state and local law enforcement agencies often seize assets and proceeds from assets linked to criminal activity. The purpose of the seizures...more
It is important to weigh enforcement risks with perspective. The Justice Department’s biggest FCPA enforcement year was approximately $1.4 billion in 2010.
The Justice Department doubled that amount in the off-label...more
On June 21, 2012, the United States Supreme Court ruled that under the Sixth Amendment, before a criminal fine can be imposed for multiple days of violations of the Resource Conservation and Recovery Act, a jury, not the...more
As Justice Felix Frankfurter aptly observed, "Wisdom too often never comes, and so one ought not to reject it merely because it comes late." With certain limited exceptions, however, issues raised for the first time on appeal...more
In my October 2010 post “Don’t Talk Trash About A California Bank“, I discussed Financial Code Section 756 (subsequently reenacted verbatim as Section 1327). That statute generally criminalizes spreading false rumors about a...more
While the prosecution of former Senator Ted Stevens is long over, the fallout from the prosecutorial misconduct in that case continues. Congress is now considering legislation that attempts to ensure that federal prosecutors...more
Today was a great day for transparency and political freedom. INTERPOL refused to allow the Red Notices as requested by Egypt against the non-governmental workers who are currently sought for prosecution in Egypt. In so...more
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