Blecker: GM Recalls Show Need for Harsher Penalties for "Red Collar" Criminals
What Are the Drastic Ramifications of the New York State Anti-Money Laundering Actions and Penalty Enforcement?
Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
The New Normal: Taking Responsibility for Your Vendors
Lessons Learned from the BizJet Executives FCPA Enforcement Actions
Crystal Ball Perspective: Will Healthcare Reform be Repealed if Romney Wins the Presidential Election?
Employer Shared Responsibility Penalties -
There are two types of employer shared responsibility payments, also known as pay or play penalties, under the Affordable Care Act (ACA). The first penalty under Internal...more
Entering into new, international markets may be good for developing business, but it also carries certain risks. This is particularly true in many countries where doing business may include making gifts, paying gratuities and...more
In a major change to the Offshore Voluntary Disclosure Program, the streamlined filing compliance procedures with their 5% penalty, has been opened up to non-willful violators that reside in the U.S. This is to be contrasted...more
As of April 1, 2014, California hospitals are subject to a significantly increased risk of being fined when state authorities find deficiencies in their compliance with licensing requirements and other health care-related...more
The importance of a company’s response to a Department of Justice (“DOJ”) investigation into possible violations of the Foreign Corrupt Practices Act (“FCPA”) was highlighted last week when Marubeni Corporation (“Marubeni”)...more
2013 was a significant year for the UK regulatory landscape. National and international regulators continued to address the issues identified by the financial crisis in addition to responding to the LIBOR scandal with...more
On December 11, the FCA published a final notice to Lloyds Banking Group in which it was fined a record GBP £28 million. The fine was imposed for “serious failings” in its sales practices, the largest UK regulatory penalty...more
The controversy around punishment and deterrence of corporate misconduct continues to swirl. As fines increase against companies, it is important to ask the question whether the current enforcement scheme adequately punishes...more
Earlier this week the Department of Justice (DOJ) announced it had resolved an ongoing Foreign Corrupt Practices Act (FCPA) with German entity Bilfinger SE (Bilfinger). This case involved the same background facts and events...more
Confirming that no good deed goes unpunished, Florida law now requires employers to respond to all unemployment claims or face a penalty. All employers are subject to this penalty, even if the employer does not contest the...more
On October 23, the SEC announced penalties totaling $400,000 against three investment advisory firms and their executives for allegedly repeatedly ignoring problems with their compliance programs, which the SEC deemed...more
- The IRS has signaled its intent to prosecute more small businesses for relatively low-value tax violations.
- In doing so, the IRS has increased its reliance on data-driven analyses of the...more
Today is the 82nd anniversary of the reporting to Alcatraz Prison of one of its most memorable residents; Al Capone. Capone was sent to prison for income tax evasion; in other words, it was a books and records violation,...more
FinCEN’s new Enforcement Division, which was created in June of 2013, is already making its mark in the financial enforcement world.
Federal regulators are focusing on compliance with Bank Secrecy Act (“BSA”) and...more
Alternative investment fund managers based outside the European Economic Area (EEA) who wish to market their alternative investment funds (AIFs) to European investors are rightly concerned about additional restrictions and...more
As the Healthcare Landscape Shifts, Four Issues Are Critical to Build Effective Market Access Strategies -
In this time of high growth and fast change for the healthcare industry, pharmaceutical, biotechnology and...more
As immigration reform measures proceed through Congress, it is critical that employers are prepared for strict worksite enforcement of I-9 requirements to prevent costly auditing and penalties for paperwork violations or the...more
On the heels of last week’s announcement that the Affordable Care Act’s (ACA) reporting requirements and Play or Pay penalties will not go into effect until 2015, the IRS has released transition relief clarifying that the...more
One of the things that I am often asked is how are fines and penalties calculated for Foreign Corrupt Practices Act (FCPA) violations? ...more
My good friend and mentor, Judge Sporkin, is not shy nor bashful about his views on the FCPA. When he heard about DOJ’s undercover sting in the Shot Show case, he scoffed, “What a mistake! ...more
Far-reaching and critical amendments proposed by Bill S-14, An Act to amend the Corruption of Foreign Public Officials Act, received royal assent on June 19, 2013....more
The above lyrics are the closing stanza to the song “Ghost Riders in the Sky”. I thought about the advice for the cowboy to change his ways to save his soul from Hell when I read in both the Financial Times (FT) and the Wall...more
Bill Mathias of Ober|Kaler's Health Law Group presented on compliance as a part of the 2013 Healthcare Fraud and Abuse Bootcamp Webinar Series sponsored by the American Health Lawyers Association.
In This Issue:
- Russian Civil Law Reform: Recent and Upcoming Amendments
- Anti-Corruption Laws: New Compliance Requirements for Russian Companies
..Disclosure of Beneficial Ownership
Topics we will cover:
• Issues with Control Groups
• Issues with Prohibited Transactions
• Fee Disclosure
- Excerpt from Who is in the Control Group?
• Aggregation Rules (Section...more
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