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Crystal Ball Perspective: Will Healthcare Reform be Repealed if Romney Wins the Presidential Election?
SEC Chairman Mary Jo White again made her stance on aggressive enforcement clear during her recent speech to the Council of Institutional Investors in Chicago. Speaking to a room full of investors, Ms. White outlined the...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
Long-awaited omnibus regulations (Omnibus Rule) adopted earlier this year by the Department of Health and Human Services (HHS) Office for Civil Rights (OCR) made significant modifications impacting “business associates” to...more
Two recent Federal Energy Regulatory Commission ("FERC") orders will result in the imposition of civil penalties totaling nearly three quarters of a billion dollars on Barclays Bank PLC ("Barclays") and JP Morgan Ventures...more
The Federal Energy Regulatory Commission’s (FERC) August 5, 2013, $28 million show cause order against BP America Inc. and other BP affiliates highlights the interrelationship between the Commodity Futures Trading Commission...more
The District of Columbia Circuit Court of Appeals, in Kourouma v. FERC, (Docket No. 11-1283, July 23, 2013), has set new precedent affirming FERC’s authority to enforce penalties for a seller’s violation of its Market...more
On 17 May 2013, The Department of Industry, Innovation, Climate Change, Science Research and Tertiary Education released its report (Report) following an independent review of the Franchising Code of Conduct (Franchising...more
Idaho State University (ISU) was recently the target of an investigation and enforcement action for violations of the privacy and security rules of the Health Insurance Portability and Accountability Act (HIPAA)....more
This past Thursday, the CFPB announced that it filed a complaint against a Florida debt-relief company that misled consumers across the country. Following an investigation into American Debt Settlement Solutions, Inc. (ADSS)...more
The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) sets forth rules to protect the privacy and security of individuals’ health information that is held by “covered entities,” such as group health plans....more
The U.S. Securities and Exchange Commission (“SEC”) recently issued an Order Instituting Proceedings (“Order”) against the administrator and compliance services provider, as well as current and former members of the boards of...more
On Friday May 17 2013, the Australian Government released the latest in a long line of Federal and State enquiries into the regulation of franchising in Australia....more
Unknown to many manufacturers of appliances, energy-consuming devices and water fixtures, there are a host of energy conservation standards that regulate the performance of these products. While the energy conservation...more
My sources tell me that the Consumer Financial Protection Bureau (CFPB) will soon announce substantial monetary penalties and other administrative actions against a large nonbank. I guess it is inevitable that when such an...more
On January 25, 2013, the Office of Civil Rights (OCR) of the Department of Health & Human Services (HHS) published the long-awaited omnibus final regulation governing health data privacy, security and enforcement (Omnibus...more
In the three months since the Communist Party of China (the “CPC”) convened its 18th National Congress in November 2012, the CPC’s new leaders, including newly appointed CPC General Secretary and China’s incoming president Xi...more
- This month several U.S. Senators introduced the Preserve Access to Affordable Generics Act. There is no similar bill pending in the U.S. House.
- The Act revives legislative efforts to wipe out the...more
Changes to the HIPAA Enforcement Rule -
Background: On October 30, 2009, HHS issued an interim final rule revising the Enforcement Rule to incorporate provisions of the HITECH Act. The NPRM then proposed a number of...more
The Health Insurance Portability and Accountability Act/Health Information Technology for Economic and Clinical Health Act Omnibus Rule, published in the Federal Register Jan. 25, makes many changes to the HIPAA Privacy Rule,...more
In an action that will have broad implications for drug and device manufacturers, researchers, distributors, teaching hospitals and physicians, on February 1, the Centers for Medicare and Medicaid Services (CMS) publicly...more
The U.S. Department of Health and Human Services (HHS) issued final regulations last week that modify many aspects of the privacy and security rules under the Health Insurance Portability and Accountability Act (HIPAA) and...more
In This Issue:
Overview Of Insider Trading Law; 2012 Enforcement activity; Galleon Update; Expert Network Cases; What Does Cooperation Buy You?; Global Trading, Global Enforcement; Legislative Reform; 10b5-1 Plans: Not...more
Under the headline “EPA Enforcement in 2012 Protects Communities from Harmful Pollution,” the U.S. Environmental Protection Agency (EPA) on December 17, 2012, released its annual report of enforcement activities for the 2012...more
Executive Summary: False Claims Act actions against government contractors are on the rise. But two recent decisions offer potential limitations to false claims exposure, and may aid defendants in future FCA litigation....more