Earlier this year, as described in a previous client alert, the Department of Justice (“DOJ”) Criminal Division announced a landmark pilot program to pay monetary awards to whistleblowers (the “Program”). At that time, Deputy...more
8/9/2024
/ Asset Recovery ,
Bribery ,
CFTC ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
FEPA ,
Financial Crimes ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Healthcare Fraud ,
Incentives ,
Money Laundering ,
Popular ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers
On March 18, 2024, Ismail Ramsey (“Ramsey”), the U.S. Attorney for the Northern District of California (“NDCA”), announced the launch of NDCA Whistleblower Pilot Program (the “Pilot Program”), a significant new policy that...more
On March 7, 2024, Deputy Attorney General (“DAG”) Lisa Monaco announced a new Department of Justice (“DOJ”) pilot program to pay whistleblower rewards (“the Program”) for individuals who report corporate misconduct. As the...more
On January 10, 2024, Damian Williams, the U.S. Attorney for the Southern District of New York (“SDNY”), announced the launch of the SDNY Whistleblower Pilot Program (the “Pilot Program”), a significant new policy that...more
Ten years in the making, and full implementation is finally coming. In about a year—beginning on November 27, 2023—prescription drug manufacturers and their supply chain partners will be required to fully trace and verify...more
PART I-
On April 20, 2022, the Office of Inspector General (“OIG”) of the Department of Health and Human Services (“HHS”) issued Advisory Opinion, No. 22-07 (“Opinion 22-07”), an informative opinion regarding arrangements...more
8/30/2022
/ Anti-Kickback Statute ,
Beneficiaries ,
Business Ownership ,
Carve Out Provisions ,
Department of Health and Human Services (HHS) ,
Fraud Alerts ,
Irrevocable Trusts ,
Medical Devices ,
OIG ,
Ownership Interest ,
Physician Ownership