Trends in FCPA Compliance and Enforcement for 2014
What Is Driving Stepped Up Government Health Care Enforcement? – Interview with Hope Foster, Member, Mintz Levin
SEC News - Five Year Enforcement Limitation, FCPA Charges for Foreign Nationals, More...
Should Wall Street Fear Mary Jo White?
On November 18, at an American Bar Association/American Bankers Association conference on the Bank Secrecy Act/Anti-Money Laundering (BSA/AML), Deputy Attorney General (Deputy AG) James Cole challenged financial institutions’...more
Just when you thought something was a “trend,” the Department of Justice adopts a new policy approach. This year has been a very active enforcement year – the strongest year of FCPA enforcement since 2010....more
On November 19 and 20, 2013, the American Conference Institute held the 30th annual U.S. Foreign Corrupt Practices Act (“FCPA”) conference outside of Washington, D.C. In addition to keynote addresses by U.S. Department of...more
Companies all over the globe are increasingly aware of the record number of corporate criminal enforcement actions brought in recent years by enforcement authorities to combat corruption, and many companies now are also...more
Regulators speaking at the American Conference Institute’s 30th International Conference on the Foreign Corrupt Practices Act tout large penalties, enhanced international cooperation, and a renewed focus on individual...more
“The U.S. government is too restrictive in trying to prevent its companies from corruption abroad and that’s hurting business expansion in Asia and elsewhere, according to Penn National Gaming Chairman Peter...more
Recent SEC Enforcement Developments -
.. Change in SEC policy regarding “no admissions” settlements
- SEC Chair Mary Jo White has joined with colleagues at DOJ to change the perception that U.S. companies are...more
United States Department of Justice issues further information on amnesty program for Swiss banks, including details on the selection of an Independent Examiner.
On November 5, 2013, United States Department of Justice...more
The U.S. Government Accountability Office (GAO) recently published a report analyzing the effectiveness of Health Care Fraud and Abuse Control (HCFAC) program activities titled, “Indicators Provide Information on Program...more
Ed. Note-in light of Avon’s recent disclosures regarding its negotiations to resolve its outstanding FCPA issues, I thought about what a shareholder might say to the Board. Today’s post are those musings…
Thirty groups have written to the CFPB, FTC, Department of Justice and federal banking regulators urging them “to closely monitor the payment processing procedures and compliance safeguards in place” at the payment processors...more
A recent SDNY ruling strengthens the Department of Justice’s expanding application the Financial Institutions Reform, Recovery and Enforcement Act of 1989.
UPDATE On October 23, a jury returned the first FIRREA...more
Discussion and Analysis -
Most of us have seen those top-rated TV commercials for a wireless provider featuring a conservatively dressed man sitting at a little table with several children and asking them, “Is it...more
Mapping The New Fraud And Abuse Landscape -
In an age of increased government scrutiny and enforcement, providers, payers, pharmaceutical companies and medical device manufacturers, along with their business partners,...more
Sometimes the universe converges in ways that are quite eerie. This past weekend was such an instance when the most beloved figure in Houston professional sports passed on to the great hereafter; only to be followed two days...more
The Department of Justice is targeting individuals for criminal FCPA violations. As I have discussed before, DOJ is bringing strong cases with overwhelming evidence against individual defendants. ...more
Most organizations engage with hundreds, if not often thousands, of third party vendors, suppliers, agents and business partners, creating a daunting and ever-expanding scope of risk.
This risk arises from:
The recent meeting of the G-20 countries, produced an agreement titled “Exchange of information: Convention on Mutual Administrative Assistance in Tax Matters”. One of the key provisions calls for a global exchange of banking...more
The US Department of Justice (DOJ) announced it is relaxing its marijuana enforcement policy and will not challenge state laws legalizing marijuana use for either medical or recreational purposes. This announcement comes in...more
The interest of regulators and enforcement authorities in short-term, small-dollar credit products – including payday loans, advance deposit products, installment loans, and more – has intensified in 2013. State and federal...more
As BakerHostetler recently reported in its FCPA Mid-Year Update, the phenomenon of parallel prosecutions is gaining popularity as more countries enact and enforce anti-corruption legislation....more
Yesterday I used the lyrics from Emerson, Lake and Palmer’s song Karn Evil No. 9, First Impression, Pt. 2 - “Welcome Back My Friends, To The Show That Never Ends” as an entrée into the topic of the investigation of JP...more
At least six federal agencies, including the U.S. Department of Justice (DOJ), the Consumer Protection Financial Bureau (CFPB), and the Federal Trade Commission (FTC), are currently coordinating a broad crackdown of the...more
FHFA Input on Freddie Mac and Fannie Mae Multifamily Businesses -
On August 9, the FHFA announced that it is seeking public input on strategies to reduce Fannie Mae and Freddie Mac's presence in the multifamily housing...more
Bill Baer assumed his post as leader of the U.S. Department of Justice (DOJ) Antitrust Division in January of this year and is starting to make his mark....more