Enforcement Actions Compliance

News & Analysis as of

HIPAA Security Requirements Aren't Cloudy, Especially to Whistleblowers

Earlier this month, the U.S. Department of Health and Human Services Office for Civil Rights (HHS OCR) announced that it had entered into a settlement agreement with St. Elizabeth's Medical Center (SEMC) in Brighton,...more

What Would Dr. Seuss Say about an Allowance?

Earlier this month we had the release of a second book by Harper Lee, “Go Set a Watchman”, which was miraculously discovered having been written some 50+ years ago. This week, there was another release from a (now deceased)...more

Private Equity FCPA Enforcement

FCPA enforcement efforts are not so hard to follow and predict – the government likes to provide advance warnings as an effective means of deterrence. Justice Department and SEC officials will often tell the public their...more

Rare SEC Administrative Loss in Adviser ADV Case

SEC Administrative Law Judge Grimes dismissed administrative charges against an investment adviser and its principals for allegedly failing to disclose material conflicts of interest in its Form ADV and willfully filing false...more

A Review of Recent Whistleblower Developments

SEC Awards Another Whistleblowing Compliance Officer - On April 22, 2015, the Securities and Exchange Commission (SEC) announced an award between $1.4 and $1.6 million to a compliance officer who provided information...more

BSA, AML Failures by West Virginia Bank Yield FDIC, FinCEN, DOJ Actions

Why it matters - In a coordinated effort, the U.S. government identified another “poster child” to demonstrate its continued vigilance and earnestness in pursuing lax BSA/AML procedures and oversight and violations of...more

OCR Enforcement Trends

On April 27, 2015, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) announced a resolution agreement with Cornell Prescription Pharmacy (CPP) pursuant to which CPP paid a $125,000...more

Under scrutiny: Internal investigations - Internal investigations are becoming increasingly commonplace, but how do you cope when...

There has been a sustained rise in investigations and enforcement actions taken by regulatory authorities in the wake of the financial crisis. As companies try to get back on track, internal investigations have also become...more

Corporate Investigations & White Collar Defense - June 2015

The Unfolding FIFA Scandal: Will the DOJ Show the Banks a Red Card? - Why it matters: The worldwide soccer community has for years decried the brazen corruption that permeated FIFA, international soccer’s governing...more

West Virginia’s Bank of Mingo Pays $4.5 Million for BSA/AML Compliance Program Deficiencies, Showing that Small and Midsize...

A series of recent federal enforcement actions targeting weaknesses in financial institutions’ Bank Secrecy Act/anti–money laundering (BSA/AML) compliance programs continued on June 15, when the Department of Justice (DOJ),...more

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

FinCEN Enforcement Stacks the Deck in AML Compliance for Casinos and Card Clubs

Stephanie Booker, Associate Director for Enforcement, Financial Crimes Enforcement Network (“FinCEN”), recently gave a speech at the Nevada Bar Association’s Bank Secrecy Act Conference in Las Vegas. Involved in the...more

AML Compliance Expectations Unabated—Fines, Enforcement Actions and a Deferred Prosecution Agreement Against Banks, Money...

Why it matters - Three Financial Crimes Enforcement Network (FinCEN) orders, three sets of fines and asset forfeitures, a deferred prosecution agreement and one bank enforcement action demonstrate the resolve of the...more

FCPA Compliance and Ethics Report-Episode 172-Scott Killingsworth on Personal Liability of CCOs [Video]

In this episode I visit with Scott Killingsworth on the recent SEC enforcement action in the SFX matter. In that case, the SEC held the CCO personally liability. We discuss the underlying facts, prior SEC pronouncements the...more

SEC Rolls Out First Wave of MCDC Settlements with Underwriters

Last Thursday, the SEC announced it reached settlement agreements with 36 municipal securities underwriting firms pursuant to its Municipalities Continuing Disclosure Cooperation (MCDC) Initiative.  These settlements mark...more

FCPA Compliance and Ethics Report-Episode 171-FCPA Enforcement in the Energy Industry [Video]

In this episode I discuss enforcement of the FCPA in the energy industry, it genesis and the business response by the energy industry. ...more

George Carlin and Erga Omnes: the Petrobras Bribery Scandal Expands

On this date in 2008 George Carlin died. If you grew up in the late 1960s or early 1970s and you had anti-parental or anti-establishment inklings, which of course all teenagers do, you knew about George Carlin. In the early...more

EPA Updates Its Audit Policy with "eDisclosure"

On June 10, 2015, the U.S. Environmental Protection Agency hosted a webinar describing a plan to modernize the implementation of its April 11, 2000 Audit Policy. The plan – called eDisclosure – attempts to provide a...more

The Costs and Risks of Corruption: Impacts beyond the Bribe

Anti-corruption news often revolves around the costly criminal and civil enforcement penalties paid by companies caught in corruption scandals. In the U.S., those costs often reach the hundreds of millions of dollars and are...more

FinCEN Fines Michigan MSB For BSA/AML Violations, Bans Owner From Serving at Any U.S. Financial Institution

On May 29, a Michigan-based money service business (MSB), along with its owner, admitted to repeated violations of the BSA and have agreed to pay FinCEN a civil money penalty in the amount of $12,000. The company violated the...more

FCPA Compliance and Ethics Report-Episode 168-Dan Cogdell on criminal procedure issues in defending an individual prosecuted... [Video]

In this episode I visit with well-known criminal defense attorney Dan Cogdell. He talks about some of the issues around defending individuals involved in a criminal-side FCPA enforcement action including: criminal procedure,...more

U.S. EPA – Next Generation Enforcement – Already Here With More Coming Soon

The 2016 budget focus for the United States Environmental Protection Agency (“U.S. EPA”) is on continued implementation of its “Next Generation” enforcement initiative, and this could mean big costs for manufacturers who...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

Recommended Actions for Hedge Fund, Private Equity Fund and Other Private Fund Advisers To Prevent Possible Whistleblower...

On April 1, 2015, the Securities and Exchange Commission (SEC) announced that it had settled its first enforcement action under SEC Rule 21F-17, which prohibits companies from taking actions or using confidentiality...more

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