On May 12, Matthew R. Galeotti, the head of the US Department of Justice’s (DOJ) Criminal Division, announced a new white collar enforcement plan, outlined changes to the Corporate Enforcement and Voluntary Disclosure Policy,...more
This past September, the US Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs (ECCP). The revised guidance reflects the government’s evolving expectations regarding corporate responsibility...more
11/18/2024
/ Anti-Retaliation Provisions ,
Artificial Intelligence ,
Code of Conduct ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Employee Training ,
Incentives ,
NIST ,
Risk Management ,
Technology ,
Whistleblower Hotlines ,
Whistleblowers
On March 7, at the annual American Bar Association (ABA) National Institute on White Collar Crime, US Deputy Attorney General (DAG) Lisa Monaco announced a new whistleblower program that will provide financial rewards to...more
3/19/2024
/ Attorney General ,
CFTC ,
Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Pilot Programs ,
Regulatory Agenda ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
Court Rules Prescription Drug Event and Enrollee Encounter Data Are 'Claims for Payment' Under the False Claims Act -
US District Judge Noel L. Hillman approved a whistleblower’s request to file a Fourth Amended Complaint...more
4/26/2021
/ Centers for Medicare & Medicaid Services (CMS) ,
Department of Justice (DOJ) ,
Fair Market Value ,
False Claims Act (FCA) ,
Healthcare Fraud ,
Kickbacks ,
Mail Fraud ,
Medicaid ,
Medicare Part A ,
Medicare Part D ,
Oil & Gas ,
Securities Fraud ,
Whistleblowers ,
Wire Fraud
Urgent Care Provider and Management Company to pay $22.5 Million to End FCA Claims -
South Carolina urgent care providers agreed to pay $22.5 million to resolve False Claims Act claims filed by two former employees. The...more
4/19/2021
/ Corporate Integrity Agreement ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Medicaid ,
Medicare ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Settlement ,
TRICARE ,
Whistleblowers ,
Wire Fraud
Supreme Court Declines to Review Issue of “Objective Falsity” Under False Claims Act -
On February 22, 2021, the United States Supreme Court denied petitions for certiorari in a case that could have addressed the issue of...more
3/1/2021
/ Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Fraud ,
Health Care Providers ,
Healthcare Fraud ,
Hospice ,
Investment Fraud ,
Objective Falsity ,
Qui Tam ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Whistleblowers
DOJ’s 2020 False Claims Act Recoveries Lowest Since 2008 -
On January 14, 2021, the Department of Justice (DOJ) announced that it obtained more than $2.2 billion in settlements and judgments from civil cases involving...more
1/25/2021
/ Bribery ,
CARES Act ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Federal Food Drug and Cosmetic Act (FFDCA) ,
Food and Drug Administration (FDA) ,
Fraud ,
IRS ,
Kickbacks ,
Medicaid ,
Medical Devices ,
Paycheck Protection Program (PPP) ,
Qui Tam ,
Relief Measures ,
SBA ,
Settlement ,
Whistleblowers ,
Wire Fraud
Deutsche Bank to Pay Over $130 Million to Resolve Foreign Corrupt Practices Act and Fraud Allegations -
Deutsche Bank Aktiengesellschaft (Deutsche Bank) has agreed to pay more than $130 million to resolve the government’s...more
1/18/2021
/ Accounting Controls ,
BDC ,
Bribery ,
Bristol-Myers Squibb ,
Criminal Penalties ,
Deferred Prosecution Agreements ,
Deutsche Bank ,
Disgorgement ,
Drones ,
False Claims Act (FCA) ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Healthcare Fraud ,
Kickbacks ,
Medicare ,
Money Laundering ,
Qui Tam ,
Sanofi-Aventis ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Spoofing ,
Telemedicine ,
U.S. Navy ,
Whistleblowers ,
Wire Fraud
False Claims Act Legal Developments -
First Circuit Upholds Whistleblower Retaliation Verdict -
On December 9, 2020, the US Court of Appeals for the First Circuit held as a matter of first impression that “the...more
12/21/2020
/ Anti-Corruption ,
Appeals ,
Bribery ,
Conspiracies ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
Qui Tam ,
Retaliation ,
Title VII ,
Venezuela ,
Whistleblower Protection Policies ,
Whistleblowers
House Committee Chairs Direct White House and Federal Agencies to Preserve Documents during Transition Period to the Biden Administration -
On November 10, 2020, Committee Chairs from the House of Representatives sent...more
Russian National Sentenced to Prison for $100 Million Cyber Fraud Conspiracy -
On October 30, 2020, a Russian national was sentenced to eight years in prison for his role in a scheme to illicitly obtain and use sensitive...more
11/6/2020
/ Centers for Medicare & Medicaid Services (CMS) ,
Civil Monetary Penalty ,
False Claims Act (FCA) ,
Fraud ,
Healthcare Fraud ,
Medicare ,
Physicians ,
Qui Tam ,
Russia ,
SCOTUS ,
Sensitive Personal Information ,
Whistleblowers
Biotechnology Company Settles False Claims Act Charges for $11.5 million -
The Acting U.S. Attorney for the Southern District of New York announced a settlement with Bio-Reference Laboratories, Inc. (“BRL”), a New...more
9/28/2020
/ Anti-Fraud Provisions ,
Anti-Kickback Statute ,
Biotechnology ,
Broker-Dealer ,
False Claims Act (FCA) ,
Fraud ,
Kickbacks ,
Medicare ,
New Jersey ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
TRICARE ,
Whistleblowers
Florida Doctor Charged in $681 Million Fraud Scheme Involving Substance Abuse Treatment -
On July 30, 2020, a criminal complaint was unsealed charging Michael J. Ligotti, D.O., with conspiracy to commit health care fraud...more
8/10/2020
/ Drug Treatment ,
False Claims Act (FCA) ,
Healthcare Fraud ,
Individual Retirement Account (IRA) ,
Kickbacks ,
Medicare ,
Paycheck Protection Program (PPP) ,
Securities and Exchange Commission (SEC) ,
Substance Abuse ,
Whistleblowers ,
Wire Fraud
DME Provider to Plead Guilty to $109 Million Medicare Fraud Scheme -
A Florida-based individual was charged with one count of health care fraud and one count of payment of kickbacks in connection with a federal health care...more
8/3/2020
/ Durable Medical Equipment ,
Identity Theft ,
Kickbacks ,
Market Manipulation ,
Medicaid ,
Medicare ,
Medicare Fraud ,
NFL ,
Popular ,
Shell Corporations ,
Whistleblowers
DOJ Announces $72.3 Million False Claims Act Settlement -
Oklahoma Center for Orthopaedic and Multi-Specialty Surgery, its part-owner and management company, a physician group, and other affiliated entities and individuals...more
Ten Individuals Charged for $1.4 Billion Health Care Billing Schemem -
On June 29, an indictment was unsealed charging ten individuals with health care fraud and wire fraud for allegedly participating in a pass-through...more
7/6/2020
/ Audits ,
CARES Act ,
Coronavirus/COVID-19 ,
Healthcare ,
Healthcare Fraud ,
Indictments ,
Kickbacks ,
Medicare ,
Money Laundering ,
Rural Health Care Providers ,
SCOTUS ,
Skilled Nursing Facility ,
Universal Health Services Inc v United States ex rel Escobar ,
Whistleblowers ,
Wire Fraud
SEC Adopts Aggressive Approach to COVID-19 Fraud -
The US Securities and Exchange Commission has already initiated multiple investigations into companies seeking to illegally profit from the global coronavirus pandemic...more
5/4/2020
/ Anti-Kickback Statute ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
False Claims Act (FCA) ,
Fraud ,
Inspector General ,
Medicare ,
Pandemic ,
Securities and Exchange Commission (SEC) ,
Trading Suspension ,
TRICARE ,
Whistleblowers
Nonprofit Hospital System and Physician Practice Reach $10 Million Settlement for False Claims Act Allegations -
Centra Health Inc., a nonprofit hospital system, and Blue Ridge Ear, Nose, Throat and Plastic Surgery, Inc.,...more
4/27/2020
/ Anti-Kickback Statute ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Kickbacks ,
Maryland ,
Medicaid ,
New York ,
Patient Referrals ,
Qui Tam ,
Relators ,
Stark Law ,
State and Local Government ,
Tax Fraud ,
Whistleblower Awards ,
Whistleblowers
Supreme Court Declines to Resolve Circuit Split Over Deference Owed to Department of Justice Decisions to Dismiss Whistleblower Suits Brought Under the False Claims Act -
On April 6, 2020, the US Supreme Court denied a...more
Headlines that Matter for Companies and Executives in Regulated Industries -
DOJ News -
Tenet Healthcare Agrees to $1.41 Million Settlement of FCA Claims -
Tenet Healthcare Corporation and its affiliated hospital,...more
In the DOJ’s first-ever criminal action against an electronic health records vendor, San Francisco-based Practice Fusion Inc. agreed to pay $145 million to resolve allegations that it received kickbacks from pharmaceutical...more
2/3/2020
/ Anti-Kickback Statute ,
Criminal Penalties ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Electronic Medical Records ,
False Billing ,
False Claims Act (FCA) ,
Health Care Providers ,
Health Information Technologies ,
Healthcare Fraud ,
Investigations ,
Kickbacks ,
Opioid ,
Pharmaceutical Industry ,
Physicians ,
Prescription Drugs ,
Qui Tam ,
Software ,
Whistleblowers
Home Health Care Employees Plead Guilty in Multi-Million Dollar Medicaid Fraud Scheme -
Two individuals pled guilty in Pennsylvania federal court to conspiracy to defraud the Pennsylvania Medicaid program and commit...more
1/24/2020
/ Anti-Kickback Statute ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare Fraud ,
Home Health Agencies ,
OIG ,
Whistleblowers
DOJ News -
Manufacturer to Pay Over $37.5 Million to Resolve False Claims Act Allegations -
On January 15, 2015, the DOJ announced that ResMed Corp., a manufacturer of durable medical equipment, agreed to pay over...more
1/20/2020
/ Anti-Kickback Statute ,
Clinical Trials ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Health Care Providers ,
Healthcare Fraud ,
Indictments ,
Misrepresentation ,
Physicians ,
Qui Tam ,
Settlement ,
Tax Deductions ,
Tax Fraud ,
Tax Returns ,
Whistleblowers
Omnicare and CVS Face Fraudulent Billing Lawsuit -
On Tuesday, the US Attorney’s Office for the Southern District of New York announced a False Claims Act lawsuit against Omnicare, Inc. and its parent company, CVS Health...more
12/20/2019
/ CVS ,
Department of Justice (DOJ) ,
Dismissals ,
False Claims Act (FCA) ,
Government Investigations ,
Medicaid ,
Medicare ,
Medicare Part D ,
Omnicare ,
Pharmacies ,
Prescription Drugs ,
Rite Aid ,
State Attorneys General ,
TRICARE ,
Whistleblowers
Compound Ingredient Supplier to Pay Over $22 Million to Resolve Allegations Brought Under Qui Tam Provisions of FCA -
On November 7, 2019, the Department of Justice (DOJ) announced that Fagron Holding USA LLC (Fagron) had...more
11/18/2019
/ Alstom ,
Civil Monetary Penalty ,
Corporate Officers ,
Criminal Convictions ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Healthcare Fraud ,
Insider Trading ,
Medicare ,
Qui Tam ,
TRICARE ,
Whistleblowers