The U.S. Court of Appeals for the 11th Circuit recently ruled on an issue lying at the intersection of fraud conspiracies and the U.S. Sentencing Guidelines: the government’s separate burden of proof against each co-defendant...more
On April 12, 2013, the Department of Justice announced changes to the Antitrust Division’s carve out practices concerning negotiations with companies that plead guilty to criminal antitrust violations. These changes were...more
Assistant Attorney General Bill Baer in charge of the Department of Justice’s Antitrust Division recently announced changes to the division’s “carve-out practice” regarding corporate plea agreements. The changes aim to...more
In this issue: - FINRA and ISG Extend Effective Date for Certain Electronic Blue Sheet Data Elements - NFA Amends FCM Capital Requirements for Forex Transactions with ECPs - Delaware Supreme Court Upholds...more
On Friday, April 12, 2013, the Antitrust Division of the United States Department of Justice announced a reversal in policy relating to its negotiations with companies that plead guilty of criminal antitrust violations.1 The...more
The Criminal Tax Division of the U.S. Dept of Justice (DOJ)is taking the position that when a taxpayer has “willfully” failed to file a Report of Foreign Bank or Financial Account, an FBAR, and has in addition filed false...more
To paraphrase a famous quote, "Those who do not learn from history are doomed to repeat it," and providers who ignore the significance of the federal government's healthcare fraud enforcements efforts in 2012 do so at their...more
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