On March 5, 2025, SuperValu, Inc. (SuperValu), a grocery store chain that operates in-store pharmacies, was cleared of liability by a Central District of Illinois federal jury—finally quashing whistleblower claims that the...more
3/11/2025
/ Damages ,
False Claims Act (FCA) ,
Fraud ,
Government Agencies ,
Healthcare Fraud ,
Litigation Strategies ,
Medicaid ,
Medicare ,
Scienter ,
SCOTUS ,
US ex rel Tracy Schutte et al v SuperValu Inc et al ,
Whistleblower Protection Policies ,
Whistleblowers
Yesterday, a federal district court in the Middle District of Florida issued a decision that threatens the federal government’s continued reliance on the False Claims Act (“FCA”) as the most powerful weapon in the Department...more
More than two years after announcing the first round of settlements in the ongoing “off-channel communications” probe, the SEC recently announced another round of settlements with 26 financial firms, totaling $390 million in...more
In December 2023, President Biden signed the new Foreign Extortion Prevention Act (FEPA), closing a gap in the Foreign Corrupt Practices Act (FCPA) by criminalizing the “demand side” of foreign bribery. While the FCPA...more
Over the last several years, the Securities and Exchange Commission (“SEC”) has been laser-focused on the use of so-called “off-channel communications” in the financial services industry. On the theory that employees’ use of...more
4/22/2024
/ Books & Records ,
Broker-Dealer ,
Electronic Communications ,
Employees ,
Enforcement Actions ,
Financial Services Industry ,
Investigations ,
Investment Adviser ,
Mobile Apps ,
Mobile Devices ,
Private Equity ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations
Just one day after Deputy Attorney General Lisa Monaco announced the U.S. Department of Justice’s (“DOJ’s” or “Department’s”) whistleblower pilot program on March 8, 2024, the DOJ’s Criminal Division highlighted its plans to...more
The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more
1/11/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Broker-Dealer ,
BSA/AML ,
Financial Crimes ,
Financial Institutions ,
Investment Adviser ,
Money Laundering ,
Proposed Regulation ,
Proposed Rules ,
Recordkeeping Requirements ,
Reporting Requirements ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more
On December 13, 2023, CoinList Markets LLC (“CoinList”) agreed to pay $1,207,830 pursuant to a settlement agreement with the Office of Foreign Assets Controls (“OFAC”) in connection with allegations that the San Francisco...more
On December 14, 2023, with bipartisan support, Congress passed the Foreign Extortion Prevention Act (“FEPA”), making it a federal crime for any foreign government official to demand, receive, or agree to receive a bribe from...more
Written by Paul Desmond in the key of E-flat minor and performed by the Dave Brubeck Quartet using a funky quintuple (5/4) time, “Take Five” is and was the biggest selling jazz single of all time. But it is also slang for...more
The U.S. authorities are increasingly taking actions against big-name crypto mixers for potential violations of sanctions regulations. On November 29, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control...more
Last week, the Department of Justice (“DOJ”) announced it declined to prosecute Lifecore, a U.S. biomedical company, after Lifecore voluntarily disclosed that a company it acquired paid bribes to Mexican officials and...more
On September 29, 2023, Albemarle Corporation (“Albemarle”), a global chemical manufacturer, reached an agreement with the U.S. Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) to resolve...more
Over the last several years, the Securities and Exchange Commission (the “SEC”) and the Commodities Futures Trading Commission (“CFTC”) have been laser-focused on the use of so called “off-channel communications” in the...more
5/26/2023
/ Books & Records ,
Broker-Dealer ,
CFTC ,
Electronic Communications ,
Employees ,
Financial Institutions ,
Instant Messaging Apps ,
Investigations ,
Investment Adviser ,
Mobile Apps ,
Mobile Devices ,
Policies and Procedures ,
Securities and Exchange Commission (SEC) ,
Social Media ,
Swap Dealers
Over the last year, the U.S. Securities and Exchange Commission (“SEC”) has been laser-focused on the use of personal devices by employees of the large Wall Street banks to conduct company business. The SEC’s investigations...more
Federal agencies aggressively pursued enforcement actions in June. At the same time, state and federal regulators continued to recognize the importance of blockchain industry regulation by putting forth significant policy...more
In May, we saw a slower month for crypto enforcement actions by state and federal regulators. See our March 2022 Crypto Enforcement Actions Roundup blog here where we discuss the regulatory guidance and jurisdiction of...more
6/7/2022
/ Blockchain ,
California ,
CFTC ,
Corporate Counsel ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
FinCEN ,
Governor Newsom ,
Popular ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
A major California-based health care system, Sutter Health, and several of its medical practice foundation affiliates have agreed to pay a total of $90 million to settle allegations that they violated the False Claims Act...more
9/14/2021
/ Centers for Medicare & Medicaid Services (CMS) ,
Corporate Integrity Agreement ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Healthcare Fraud ,
Medicare ,
Medicare Advantage ,
Risk Adjustment Formula ,
Settlement ,
Whistleblowers
On August 5, 2021, the U.S. Court of Appeals for the Second Circuit ruled that a French banker may seek dismissal of an indictment without having to physically appear in the United States. The decision limits the...more