White Collar Watch - August 2012


In This Issue:

- Companies that Source Pharmaceutical and Food Ingredients in the People’s Republic of China Should Take Heed of the Government’s Response to Recent Chromium Contamination pages 1 - 2

- D.C. Circuit Affirms Exclusion from Federal Health Care Programs Under “Responsible Corporate Officer” Doctrine — with a Twist pages 3 - 4

- Congress Considering Significant Increase in SEC Penalties pages 4 - 5

Excerpt from D.C. Circuit Affirms....

On July 27, 2012, in the closely watched case of Michael Friedman, et al. v. Kathleen Sebelius, et al., the United States Court of Appeals for the D.C. Circuit held that pharmaceutical corporate executives found guilty of misdemeanor “misbranding” under the “responsible corporate officer doctrine” (“RCO doctrine”) had committed a “misdemeanor relating to fraud”— the standard for exclusion from federal health care programs pursuant to 42 U.S.C. § 1320a-7(b)(1).

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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