On February 18, 2025, the First Circuit Court of Appeals issued its decision in U.S. v. Regeneron Pharmaceuticals, ruling that the Anti-Kickback Statute (“AKS”) requires the government to prove that an AKS violation was the...more
On February 10, 2025, President Trump issued an executive order (EO) directing Attorney General Pam Bondi to effectively pause the Justice Department’s enforcement of the Foreign Corrupt Practices Act (FCPA). This was the...more
2/17/2025
/ Anti-Corruption ,
Attorney General ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Securities and Exchange Commission (SEC) ,
Trump Administration
On February 5, 2025, on her first day in office, U.S. Attorney General Pam Bondi issued fourteen memos outlining new policies for the U.S. Department of Justice (“DOJ”) in a broad range of enforcement arenas. Among these Day...more
2/7/2025
/ Anti-Corruption ,
Attorney General ,
Corporate Counsel ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Policy ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
White Collar Crimes
On January 8, 2025, Governor Maura Healey signed House Bill 5159 into law, toughening the rules and increasing the risks for private equity (PE) companies, real estate investment trusts (REITs), and management services...more
2/5/2025
/ Compliance ,
False Claims Act (FCA) ,
Healthcare ,
Healthcare Fraud ,
Investors ,
New Regulations ,
Popular ,
Private Equity ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Requirements ,
REIT ,
Reporting Requirements ,
Risk Management
I. Scope of Executive Order 14173 -
Executive Order 14173, issued on January 21, 2025, aims to end illegal discrimination and restore merit-based opportunities by ceasing diversity, equity, and inclusion (DEI) policies,...more
2/5/2025
/ Anti-Discrimination Policies ,
Compliance ,
Department of Justice (DOJ) ,
Diversity ,
Diversity and Inclusion Standards (D&I) ,
Employment Discrimination ,
Executive Orders ,
False Claims Act (FCA) ,
Federal Contractors ,
Federal Funding ,
Trump Administration ,
Whistleblowers
This is the third in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more
We kick off our annual Year in Preview series with a comprehensive look at health care fraud enforcement in 2025. This post proceeds in three parts. First, we explore what the second Trump administration might bring, looking...more
1/13/2025
/ Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
False Claims Act (FCA) ,
Food and Drug Administration (FDA) ,
Fraud ,
Healthcare Fraud ,
Medicare ,
Medicare Advantage ,
White Collar Crimes
Courts continue to reject aggressive Anti-Kickback Statute (“AKS”) allegations. Most recently, on January 6, 2025, Judge Patti Saris of the U.S. District Court for the District of Massachusetts dismissed a qui tam action...more
1/8/2025
/ Anti-Kickback Statute ,
Causation ,
Enforcement Actions ,
False Claims Act (FCA) ,
Healthcare ,
Healthcare Fraud ,
Medicare ,
Statutory Interpretation ,
Summary Judgment ,
Whistleblowers ,
White Collar Crimes
There was a noteworthy False Claims Act (FCA) settlement made public yesterday out of the Eastern District of California involving Oroville Hospital. The government accused the Hospital of submitting false claims to Medicare...more