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DOJ Breaks its Silence in 2015 FCPA Enforcement

Last week, the DOJ announced its first corporate enforcement action under the Foreign Corrupt Practice Act (“FCPA”) for 2015. IAP World Services, Inc., a Florida-based defense and government contractor, agreed to pay $7.1...more

Government Contracting Abroad: Beware Compliance Risks

On June 16, 2015, IAP Worldwide Services Inc., a private defense and government contracting company, agreed to pay $7.1 million to settle criminal charges of the U.S. Foreign Corrupt Practices Act (FCPA) related to bribing...more

Blog: OIG Reports Targeting Medicare Part D Fraud Issued on the Heels of National Medicare Fraud Sweep

The Health and Human Services (HHS) Office of Inspector General (OIG) released two reports yesterday related to Medicare Part D fraud. The OIG report, Ensuring the Integrity of Medicare Part D, “synthesizes numerous OIG...more

[Webinar] How EU Companies Can Implement & Demonstrate Effective Anti Bribery Compliance in Emerging Markets - July 9, 9:00 am EST

European companies subject to FCPA jurisdiction or comparable European jurisdictions, and doing business in emerging markets such as the BRIC nations, face a rigorous compliance standard. Firms must have compliance processes...more

Canada Anti-Corruption Law May Affect FCPA Enforcement

On June 1, 2015, Canada’s Extractive Sector Transparency Measures Act (“ESTMA”) came into force. Approved in December 2014, but not in force until this month, the act requires companies in the extractive sector to report...more

Campaign Coordination: Warning to Political Candidates and Related Super PACs

Tyler Harber’s prosecution, and the two year federal prison sentence he recently received, are clearly warning shots across the bow of federal political campaigns around the country. And the blatant and unsympathetic nature...more

"Department of Justice Secures Sentence in First Super PAC Coordination Case"

The Department of Justice recently concluded its first criminal prosecution of coordination between an independent-expenditure-only committee (super PAC) and a campaign committee. On June 12, 2015, the U.S. District Court for...more

DOJ Reaches Agreement with Government Contracting Company and Former VP over Alleged Bribery

On June 16, the DOJ entered into a non-prosecution agreement with a Florida-based defense and government contracting company to resolve allegations that it conspired to bribe Kuwaiti officials for the purpose of securing a...more

Largest Criminal Health Care Fraud Takedown – 243 Charged and $712 Million in False Billings

On June 18, 2015, HHS Secretary Sylvia M. Burwell and DOJ Attorney General Loretta E. Lynch announced nationwide arrests in Medicare fraud schemes amounting to approximately $712 million in false billings. Attorney General...more

Blog: Key Takeaways from Government Enforcement Panel at ACI Sunshine Conference

Recently, representatives from the United States Attorney’s Office for the Northern District of Georgia, United States Attorney’s Office for the District of New Jersey, and Medicaid Fraud Control Unit (MFCU) for the Office of...more

Top Ten International Anti-Corruption Developments for May 2015

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month with links to primary...more

Does the World Need Another Compliance Provider? – Part 1

Richard Bistrong was an International Sales Vice-President in the Defense Sector for most of his career, spending an average of 250 days per year overseas, and twice residing in the United Kingdom. In 2007, the US Department...more

Two Sides of A Global Corruption Investigation at Anti-Corruption Oslo

This is the second part of my interview with Robert (“Bob”) Appleton, which is timely given our question and answer session at the upcoming Anti-Corruption Conference, Oslo, where we will engage in an interview titled...more

Mintz Levin Health Care Qui Tam Update - Recently Unsealed Whistleblower Cases: June 2015

Trends & Analysis: ..We have identified 33 health care–related qui tam cases that have been unsealed in whole or in part since the cases covered in our last Qui Tam Update. In addition, we have also identified one case...more

School Bus Company Owners Indicted for Bid-Rigging and Fraud in Puerto Rico

On May 20, 2015, a federal grand jury in San Juan, Puerto Rico indicted five individuals for bid rigging and fraud conspiracies in connection with an auction for public school bus transportation contracts. The auction was...more

Supreme Court Says Wartime Suspension of Limitations Act Does Not Toll the False Claims Act's Statute of Limitations

In a unanimous Supreme Court decision issued May 26, 2015, Kellogg Brown & Root Services, Inc. v. United States ex rel. Carter (KBR), Case No. 12-1497, the United States Supreme Court addressed two significant False Claims...more

Bribery & Corruption in the Military. A Front-Line View (Part II) [Video]

In the second part of my interview on "The Heat" via CCTV, I discuss the temptations that front-line personnel face when dealing with overseas militaries, particularly, procurement personnel. I share how the touch points...more

KBR v. Carter–Supreme Court Holds that the First-to-File Bar Only Applies to Pending Cases

On Wednesday the Supreme Court, in Kellogg Brown & Root Services, Inc. v. United States ex rel. Carter, No. 12-1497 (2015), held that the Wartime Suspension of Limitations Act (“WSLA”) only tolls the statute of limitations...more

Supreme Court Update: Wellness International Network, Ltd. V. Shariff (13-935); Commil USA, LLC V. Cisco Systems, Inc. (13-896)...

This past week the Court released important decisions in the areas of bankruptcy law (Wellness International Network, Ltd v. Shariff (13-935), patent law (Commil USA, LLC v. Cisco Systems, Inc. (13-896), and the False Claims...more

Supreme Court: Wartime Suspension of Limitations Act does not apply to civil claims; ruling may also mean more criminal...

Last week, the Supreme Court handed down its decision in Kellogg, Brown & Root Services, Inc. v. U.S. ex rel. Carter. This case concerned the Wartime Suspension of Limitations Act (WSLA), a statute that suspends the statute...more

Corporate Investigations & White Collar Defense - May 2015

It’s an Absolute Privilege to Meet You! Texas Supreme Court Rules That Internal Investigation Report Provided by Shell Oil to DOJ Enjoys “Absolute Privilege” - Why it matters: On May 15, 2015, the Texas Supreme Court...more

Robert Appleton: It’s FCPA Compliance or Vegas

Today is the first of a two part interview with Robert “Bob” Appleton and is an edited version of the entire interview which will be available for download when part II is published next week....more

Supreme Court Reins In Qui Tam FCA Limitations But Allows Revival of Cases Initially Barred Under First-To-File Rule, Kellogg...

On May 26, 2015, the Supreme Court unanimously rejected efforts of False Claims Act (FCA) qui tam relators to use the Wartime Suspension of Limitations Act (WSLA) to extend the statute of limitations for their actions. In...more

Unanimous Supreme Court Rejects Wartime Tolling of Statute of Limitations for Civil False Claims but Opens Door to Successive Qui...

On May 26, 2015, the United States Supreme Court resolved uncertainty surrounding the application of wartime tolling of the statute of limitations under the civil False Claims Act (FCA), but simultaneously opened the door to...more

"Supreme Court Decision in FCA Case Both a Win, Setback for Health Care Providers"

On May 26, 2015, the U.S. Supreme Court issued a rare unanimous decision in a False Claims Act (FCA) case that cuts both ways for the health care industry. In an opinion authored by Justice Samuel Alito, the Court held in...more

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