Private equity investment in health care has grown significantly over the past two decades, and the US government is starting to pay attention. Recent announcements by the US Department of Justice (DOJ) and proposals by...more
8/1/2024
/ Anti-Kickback Statute ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Healthcare ,
Healthcare Fraud ,
Investors ,
Private Equity ,
Private Equity Firms ,
Regulatory Oversight ,
White Collar Crimes
Overview - On 3 April 2024, the US Securities and Exchange Commission (the SEC) announced the first settlement with a stand-alone registered investment adviser for, among other things, failures to maintain and preserve...more
4/15/2024
/ Asset Management ,
Compliance ,
Data Preservation ,
Electronic Communications ,
Email ,
Enforcement Actions ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Firms ,
Policies and Procedures ,
Recordkeeping Requirements ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Text Messages ,
Workplace Communication
On 16 October 2023, the Division of Examinations (Division) of the US Securities and Exchange Commission (SEC) released its examination priorities for the 2024 fiscal year (the Report). The Division released this Report...more
11/3/2023
/ Anti-Money Laundering ,
Asset Management ,
Broker-Dealer ,
Capital Markets ,
Compliance ,
Corporate Counsel ,
Cryptoassets ,
Cybersecurity ,
Duty of Care ,
Enforcement Actions ,
ETFs ,
FinTech ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Firms ,
Popular ,
Securities and Exchange Commission (SEC)
On 7 February 2023, the Division of Examinations (the Division) of the U.S. Securities and Exchange Commission (SEC) announced its examination priorities for the 2023 fiscal year (the Report). The Report, which identifies...more
INTRODUCTION - On 24 January 2023, the Board of Governors of the Federal Reserve System (the FRB) announced it entered into a consent order (Consent Order) with a member bank imposing an approximately US$2.3 million civil...more
INTRODUCTION - On 7 February 2023, the U.S. Securities and Exchange Commission (SEC) Division of Examinations (the Division) released its 2023 examination priorities. As expected, the Division’s priorities highlight areas...more
In this second episode of our series on the government's response to the Paycheck Protection Program, white collar practitioners Chris Nasson, David Rybicki, Neil Smith, and Hayley Trahan-Liptak discuss the second phase of...more
This article analyzes emerging risks to PE firms that invest in the health care sector by examining the current enforcement landscape and significant FCA litigation; identifies key factors that increase FCA risk for PE firms...more
The U.S. Supreme Court’s 2019 decision in Azar v. Allina Health Services effectively curtailed the enforceability of certain Medicare policies established without notice-and-comment rulemaking. As a result, health care fraud...more
In this episode, we examine how two criminal defendants are aiming to leverage parallel FCPA investigations by the SEC and the DOJ to build their defense. We’ll also offer our thoughts on the SEC’s new (and improved?)...more
10/6/2020
/ Bribery ,
Coronavirus/COVID-19 ,
Criminal Defense ,
Criminal Investigations ,
Criminal Liability ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Discovery Disputes ,
Due Process ,
Enforcement Actions ,
Evidence ,
Evidentiary Hearings ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Honest Services Fraud ,
Memorandum of Guidance ,
New Guidance ,
OMB ,
Parallel Proceedings ,
Ruth Bader Ginsberg ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
A government inquiry can result in serious consequences for a company or individual. Our new podcast series, Voluntary Disclosure—brought to you by the lawyers in our investigations, enforcement, and white collar practice—is...more
8/3/2020
/ Best Practices ,
Bitcoin ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Initial Coin Offering (ICOs) ,
Investors ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Tokens ,
Securities Transactions ,
Securities Violations ,
Security-Based Swaps ,
U.S. Treasury ,
Unregistered Securities ,
Voluntary Disclosure ,
White Collar Crimes
A government inquiry can result in serious consequences for a company or individual. Our new podcast series, Voluntary Disclosure—brought to you by the lawyers in our investigations, enforcement, and white collar practice—is...more
7/17/2020
/ Bribery ,
Criminal Convictions ,
Denial of Certiorari ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Panama Papers ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Voluntary Disclosure ,
White Collar Crimes