Increased Foreign Agents Registration Act (FARA) enforcement is here to stay. That is the consensus view of senior Department of Justice (DOJ) officials responsible for the statute’s administration and enforcement who...more
Lavish “speaker programs” sponsored by pharmaceutical and medical-device companies may soon be a thing of the past—and not just because of the COVID-19 pandemic. In a 16 November 2020 Special Fraud Alert (Alert) issued by the...more
Borrowers of Paycheck Protection Program (PPP) loans of US$2M or more will be required to complete a new form as part of the Small Business Administration (SBA) review process, which appears to ask key questions about private...more
As many corporate practitioners know from experience, U.S. Department of Justice (DOJ) lawyers and federal prosecutors often factor a company’s inability to pay into corporate civil and criminal resolutions with the...more
Continuing to press the message that implementing and enforcing an effective compliance program is a business imperative, not an optional “best practice,” on 10 September 2020, the Commodity Futures Trading Commission (CFTC)...more
For the first time since 2014, the Department of Justice’s (DOJ) Foreign Corrupt Practices Act (FCPA) Unit has issued an opinion responding to a request for advice on compliance with the anti-bribery provisions of the FCPA. ...more
Medical necessity cases continue to be a focal point for False Claims Act (FCA) investigations and lawsuits. With this focus comes an age-old problem for health care providers and entities defending these actions: the...more
On 19 June 2020, in a major reversal of the U.S. Department of the Treasury’s (Treasury) previous position, the U.S. Small Business Administration (SBA) and Treasury announced that they will publicize additional data...more
6/26/2020
/ Borrowers ,
CARES Act ,
Coronavirus/COVID-19 ,
False Claims Act (FCA) ,
Fraud ,
Health Care Providers ,
Investigations ,
Liability ,
Loans ,
Paycheck Protection Program (PPP) ,
Public Information ,
SBA
I. INTRODUCTION - On 1 June 2020, the Criminal Division of the U.S. Department of Justice (DOJ) updated a critical guidance document, the “Evaluation of Corporate Compliance Programs” memorandum (“Guidance”), providing...more
The newly created House Select Subcommittee on the Coronavirus Crisis has launched a series of inquiries that will have lasting implications for recipients of Coronavirus Aid, Relief, and Economic Security Act (CARES Act)...more
Congress passed some $2 trillion worth of pandemic relief at the end of March, with additional relief currently under consideration. The rules governing these programs have been constantly changing. As millions of businesses...more
In response to the economic crisis caused by the spread of COVID-19, Congress passed the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) on March 27, 2020, which President Donald J. Trump subsequently signed...more