Episode 335 -- The New DOJ Whistleblower Program
Navigating the Labyrinth of Private Equity Investments in Health Care – Diagnosing Health Care
AGG Talks: Women in Tech Law Podcast - Episode 3: Cybersecurity and FCA Compliance: Essential Insights for Tech Leaders
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
#WorkforceWednesday®: New DOJ Whistleblower Program - What Employers Must Know - Employment Law This Week®
The Presumption of Innocence Podcast: Episode 43 - New Horizons: Impact of Recent Appellate Circuit Rulings on White-Collar Criminal Defense Law
Redlining Isn’t What it Used To Be
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
Episode 328 -- Sanctions Enforcement Risks and Redlines
Common Scenarios Triggering False Claims Act Violations, Part 1: Gov. Contracts and Cybersecurity
Cannabis Law Now Podcast: What’s Next for Schedule III Marijuana
Redlining Complications Caused by Implementation of 2020 Census Tracts
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
The Justice Insiders Podcast: DOJ’s Cacophony of Whistles
The Latest on Healthcare Enforcement
The Monaco memo’s imposition of CCO certification in DOJ investigations has, reasonably, been a major anxiety-inducer for compliance professionals. And while DOJ officials have said the requirement is designed to “empower”...more
Even at companies with separate legal and compliance departments, Department of Justice-enforced compliance is a key concern for in-house counsel. Those pressures only will increase in the near future and are rapidly...more
Physician Partners of America’s settlement highlights significant risks facing False Claims Act defendants who received Paycheck Protection Program funds. An April 2022 US Department of Justice (DOJ) settlement suggests...more
The compliance certification policy was first announced by Assistant Attorney General (Assistant AG) Kenneth Polite in March 2022, when he stated that for all criminal division “corporate resolutions (including guilty pleas,...more
Officials with the U.S. Department of Justice have portended a sea change in the oversight responsibilities of chief compliance officers (CCOs) as it concerns corporate resolutions going forward. In public remarks made March...more
Key Takeaways - As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...more
Last week, yet another US Department of Justice (DOJ) official reportedly stated new corporate settlements “most likely” will include a requirement that the company’s chief compliance officer (CCO), as well as the chief...more
CCOs, by definition, are careful and deliberate. It comes with the profession. As risk managers, CCOs are skilled in identifying, assessing and acting in a risk environment....more
The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers. In Part I of this series, I outlined the specific language and the Plea Agreement...more
The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action. DOJ has adopted this new requirement to...more
In a homecoming speech, DOJ’s Assistant Attorney General Kenneth Polite gave a rousing speech to a room full of compliance professionals at the annual Compliance Week meeting in Washington, D.C. AAG Polite, who has served as...more
On Tuesday, March 22, 2022, Assistant Attorney General Kenneth Polite of the Department of Justice (DOJ) told an audience of compliance professionals that DOJ will direct prosecutors to "consider requiring" chief compliance...more
On January 4, 2022, the Department of Justice (DOJ) announced a new rule governing secure storage requirements for federal firearms licensees (FFL). The new rule goes into effect on February 3, 2022. DOJ also announced that...more
CMMC 2.0 – Simplification and Flexibility of DoD Cybersecurity Requirements - Evolving and increasing threats to U.S. defense data and national security networks have necessitated changes and refinements to U.S. regulatory...more
Earlier this week, the U.S. Department of Justice (DOJ) announced the launch of its new Civil Cyber-Fraud Initiative — an effort designed to harness the department's knowledge in civil fraud enforcement, government...more
In the Spring of 2020, the Small Business Association (“SBA”) began administering the Paycheck Protection Program (the “PPP” or the “Program”) to provide SBA-backed loans to help eligible businesses maintain their workforces...more
A review of key legal developments for nonprofit organizations at the federal and state levels in 2019 and 2020. Antitrust enforcement continues against nonprofits. Nonprofits have litigated in other areas, including...more
Preventing money from getting to terrorists is a chief goal of AML programs. But at a basic level an AML program is only as strong as its budget, regardless of how good the CCO is. Can we hold CCOs criminally accountable for...more