News & Analysis as of

Internal Investigations Civil Monetary Penalty

Society of Corporate Compliance and Ethics...

Is your reporting system worth $1 million?

Answering the question of how much money a compliance and ethics program saves an organization when there’s been a violation is often a very difficult task, which presents a challenge in defending the investment in a program....more

Health Care Compliance Association (HCCA)

Due diligence and physician financial arrangements

Conducting due diligence for physician and provider compensation arrangements during a healthcare transaction is critical for the acquirer. Appropriate due diligence is necessary, regardless of whether the transaction is a...more

Holland & Knight LLP

Cooperation with SEC: Yielding More Benefits, but Lack of Predictability Remains

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Although the SEC has long adhered to its Seaboard Report of Investigation to outline the analytical framework for the agency's cooperation program for companies, the exact benefits of self-policing, self-reporting,...more

Vinson & Elkins LLP

Not Lovin’ It: SEC’s Settlement With McDonald’s Former CEO Highlights Continued Focus on Executive-Related Disclosures

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On January 9, 2023, the Securities and Exchange Commission (“SEC”) issued a cease-and-desist order (the “Order”)1 charging McDonald’s Corporation (“McDonald’s”) and its ex-CEO, Stephen Easterbrook, with multiple disclosure...more

Faegre Drinker Biddle & Reath LLP

$2.15 Million Civil Money Penalty for HIPAA Violations

The Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services imposed a $2,154,000 civil money penalty (CMP) against Jackson Health System (JHS) for violations of the Health Insurance Portability and...more

The Volkov Law Group

Quad/Graphics Settles SEC FCPA Case for Nearly $10 Million

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Quad/Graphics, a Wisconsin print and digital marketing company agreed to pay the SEC almost $10 million to settle FCPA charges for foreign bribery violations in Peru and China. ...more

Latham & Watkins LLP

Gesetzentwurf zur Bekämpfung der Unternehmenskriminalität bringt neue Regeln für interne Untersuchungen – Datenschutz gewinnt...

Latham & Watkins LLP on

Das Justizministerium arbeitet mit Hochdruck an einem Entwurf für ein Unternehmensstrafrecht. Der Entwurf verfolgt das Ziel, die Sanktionierung von Unternehmen und sonstigen Verbänden auf eine eigene gesetzliche Grundlage zu...more

UB Greensfelder LLP

Wedbush Learns That It’s Not Enough Just To Spot Red Flags

UB Greensfelder LLP on

I have been busy the last month getting ready for a big arbitration, and attending the first week of what looks like is going to be a four- or five-week slog when all is said and done. So, I am just catching up on some recent...more

Jones Day

Sanctions Enforcement Action Provides Incentives for Companies and a Warning for Individuals

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The Situation: Using a novel approach, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") concurrently designated a non-U.S. individual to the Foreign Sanctions Evaders ("FSE") List in connection...more

K&L Gates LLP

K&L Gates Triage: Internal & External Health Care Investigations

K&L Gates LLP on

In this episode, Mark Rush and John Lawrence discuss the federal government’s expectations related to health care organizations conducting internal investigations and demonstrating a commitment to compliance. The episode also...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2018

ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more

Farella Braun + Martel LLP

Steep Fines for Company With Compliance Problems, but Recognition of Remediation Efforts May Provide Model Going Forward

After a series of compliance failures leading to the resignation of company’s CEO, the privately-held health care brokerage company Zenefits was just hit with a $7 million dollar settlement by the California Department of...more

Morrison & Foerster LLP

Pay Attention to the Man Behind the Curtain: DOJ Memorandum Adds Further Weight to CPSC Enforcement Efforts Against Corporate...

The United States Department of Justice (DOJ) recently issued a memorandum to various enforcement agencies. The memorandum, available here, focuses on holding individuals accountable for corporate fraud and misconduct. The...more

Polsinelli

DOJ Reaffirms Commitment to Prosecuting Individuals, Toughens Expectation for Corporate Response

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The U.S. Department of Justice (DOJ) recently issued a memorandum ("The Yates memo") on September 9, 2015 by Deputy Attorney General Sally Yates, reaffirming the Government's commitment to prosecuting individuals. Say...more

Seyfarth Shaw LLP

SEC Cracks Down on Agreement Requiring In-House Reporting of Fraud Complaint

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The Securities and Exchange Commission (SEC) announced today that it had made good on its prior promises to take a hard look at employment agreements and policies that could be viewed as attempting to keep securities fraud...more

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