Finalized last year, the U.S. Federal Trade Commission’s (FTC) Final Rule on the Use of Consumer Reviews and Testimonials (the “Final Rule”) principally addresses the sale, purchase, and publication of fake online reviews and...more
5/27/2025
/ Advertising ,
Consumer Protection Laws ,
Disclosure Requirements ,
Enforcement Actions ,
Fake Reviews ,
False Advertising ,
Federal Trade Commission (FTC) ,
FTC Act ,
Influencers ,
Online Reviews ,
Social Media
Private placement debt offerings offer a compelling alternative to traditional lending for many companies. The legal landscape governing these transactions involves key statutes, regulations, and the critical steps required...more
Section 4(a)(2) private placements can help companies raise capital without an Initial Public Offering (IPO). While exempt from registration, these offerings do require strict compliance to avoid legal pitfalls. Companies...more
A couple of recent large-scale enforcement actions suggest that the U.S. Department of Justice (DOJ) may be placing increased emphasis on targeting black market prescription drug diversion. This is when pharmaceutical...more
3/5/2025
/ DEA ,
Department of Justice (DOJ) ,
Distributors ,
Enforcement Actions ,
Healthcare Fraud ,
Medicaid ,
Medicare ,
Pharmaceutical Industry ,
Pharmacies ,
Prescription Drugs ,
White Collar Crimes
Targeting multi-level marketers (MLMs) and other “money-making opportunity sellers” has been among the U.S. Federal Trade Commission’s (FTC) top priorities in recent years. The FTC has pursued several enforcement actions...more
2/26/2025
/ Consumer Fraud ,
Consumer Protection Laws ,
Enforcement Actions ,
False Advertising ,
Federal Trade Commission (FTC) ,
MLM ,
Proposed Rules ,
Pyramid Schemes ,
Rulemaking Process ,
Settlement ,
Unfair or Deceptive Trade Practices
The U.S. Environmental Protection Agency (EPA) is responsible for enforcing the federal laws, regulations, and Executive Orders focused on protecting the environment for the benefit of the American people, threatened and...more
7/17/2024
/ Compliance ,
Defense Strategies ,
Discovery ,
Document Review ,
Enforcement Actions ,
Enforcement Priorities ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Environmental Violations ,
Evidence ,
Investigations ,
Litigation Strategies ,
NPDES ,
Penalties ,
Risk Mitigation
The federal government is continuing to rely heavily on whistleblowers in 2024. While there are now several federal whistleblower programs, the qui tam provisions of the False Claims Act remain among the government’s most...more
A whistleblower action under the federal False Claims Act (31 U.S.C. §§ 3729 et seq.) against a U.S. pharmaceutical company has settled for an amount that can be as high as $50 million. The incident highlights the value and...more
Each year, the Office of Foreign Assets Control (OFAC) initiates several enforcement actions targeting companies, financial institutions, and individuals in the United States and abroad. These enforcement actions can present...more
Financial institutions and companies that are subject to oversight from the Office of Foreign Assets Control (OFAC) need to prioritize compliance. OFAC has become increasingly active in recent years, and it is devoting...more
9/20/2023
/ Compliance ,
Compliance Commitees ,
Compliance Monitoring ,
Cross-Border Transactions ,
Documentation ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
Financial Transactions ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Prohibited Transactions ,
Risk Assessment ,
Sanction Violations
For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more
9/8/2023
/ Blocked Entities ,
Compliance ,
Customer Due Diligence (CDD) ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Financial Institutions ,
Financial Transactions ,
Foreign Entities ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Personal Liability ,
Policies and Procedures ,
Prohibited Transactions ,
Risk Mitigation ,
Sanction Violations ,
SDN List ,
SSI List
The Office of Foreign Assets Control (OFAC) has oversight of financial transactions involving U.S. and foreign entities. It exercises this authority in several ways, including (i) through the administration of its various...more
The Office of Foreign Assets Control (OFAC) has played an increasingly important role in the federal government’s national security efforts in recent years. As transactions funding terrorist activities, criminal enterprises,...more
Company executives and stakeholders in charge of making decisions to insulate their business from legal liability by the Office of Foreign Assets Control (OFAC) at the U.S. Department of Treasury have a difficult choice to...more
Always on the lookout for unapproved drugs and supplements being sold, the U.S. Food and Drug Administration (FDA) has ramped up its enforcement actions against selective androgen receptor modulators (SARMs), which are banned...more
Financial Industry Regulatory Authority (FINRA) investigations present significant risks for broker-dealers. Not only can FINRA take enforcement action—including the imposition of penalties and barring broker-dealers from the...more
Recently, the U.S. Food and Drug Administration (FDA) confirmed that it is investigating allegations that a 60 Minutes segment on the popular body weight loss drug Wegovy was actually an advertisement promoting the...more
4/19/2023
/ Advertising ,
Criminal Prosecution ,
Enforcement Actions ,
Food and Drug Administration (FDA) ,
Health Care Providers ,
Investigations ,
Marketing ,
Novo Nordisk ,
Pharmaceutical Industry ,
Pharmacies ,
Physicians ,
Prescription Drugs
Allegations of unauthorized trading claims present significant risks for investment brokers and brokerage firms. In addition to investor arbitration with the Financial Industry Regulatory Authority (FINRA), brokers and...more
1/3/2023
/ Broker-Dealer ,
Conflicts of Interest ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Duty of Care ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Investment Fraud ,
Investors ,
Policies and Procedures ,
Regulation Best Interest ,
Regulation BI ,
Rule 10b-5 ,
Securities and Exchange Commission (SEC) ,
Securities Transactions ,
Unauthorized Transactions
Online cryptocurrency promotion—and promotion on social media in particular—has garnered national media attention in recent months. First, the U.S. Securities and Exchange Commission (SEC) announced that it had entered into a...more
12/7/2022
/ Bitcoin ,
Celebrity Endorsements ,
Cryptocurrency ,
Disclosure Requirements ,
Enforcement Actions ,
Ethereum ,
Federal Trade Commission (FTC) ,
Fraud ,
Investment ,
Investment Firms ,
Popular ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Social Media ,
TikTok ,
Transparency ,
Twitter ,
Unfair or Deceptive Trade Practices
The Foreign Corrupt Practices Act (FCPA) (15 U.S.C. § 78dd-1 et seq.) is a federal anti-bribery law that makes it unlawful for certain people to pay foreign government officials in order to conduct business abroad. While it...more
11/23/2022
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Corruption ,
Cross-Border Transactions ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Audit Functions ,
Risk Management ,
Securities and Exchange Commission (SEC)
As a licensed physician, facing a medical board investigation could mean that your career is on the line. Even though you spent years in medical school and in residency, and even though you may have spent decades honing your...more
Noncompliance with the Bank Secrecy Act (BSA) can subject banks and other financial institutions to substantial penalties. As a result, it is critical that financial institution executives not only understand the BSA itself...more
Federal law enforcement takes money laundering and other suspicious transactions extremely seriously. Unfortunately, this does not mean that legal scrutiny is confined to the criminal actors and organizations that launder...more
10/25/2022
/ Anti-Money Laundering ,
Bad Actors ,
Banking Sector ,
BSA/AML ,
Criminal Investigations ,
Criminal Prosecution ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
Money Laundering ,
Suspicious Activity Reports (SARs)
Securities litigation presents substantial risks for companies, firms, and individuals accused of violating federal law, U.S. Securities and Exchange Commission (SEC) regulations, or Financial Industry Regulatory Authority...more
The U.S. Department of Justice’s (DOJ) Consumer Protection Branch works with other branches and federal law enforcement agencies to investigate and prosecute civil and criminal violations of the nation’s consumer protection...more
10/6/2022
/ Consumer Fraud ,
Consumer Protection Laws ,
Criminal Conspiracy ,
Criminal Investigations ,
Criminal Prosecution ,
Defense Strategies ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Elder Abuse ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Food and Drug Administration (FDA) ,
FTC Act ,
Guilty Pleas ,
Healthcare Fraud ,
Mail Fraud ,
Wire Fraud