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
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
The report is the culmination of an internal audit, where the internal auditors describe what they found, provide evidence of the issues that were detected, and the corrective action that they recommend to fix them. The...more
Medical professionals, patients, and others can commit healthcare fraud by deceiving the healthcare system, such as providing medically unnecessary services, in order to get unauthorized benefits or payments. Facing...more
Pharmacy benefit manager (PBM) audits are becoming increasingly dangerous for pharmacies. While the role of the PBM was initially to reduce costs for all parties involved, abusive PBM practices have led to the opposite in...more
The United States Department of Justice (DOJ) is the federal agency tasked with enforcing a wide range of federal laws and regulations. When the DOJ suspects that an individual or business has violated a federal law or...more
For diabetic patients and the doctors who treat them, blood sugar levels are crucially important. However, the traditional method of testing one’s blood sugar with a pin-prick is undesirable for many patients, which leads to...more
Cardiovascular stress testing to diagnose patients with coronary artery disease (CAD) and other related types of conditions can be a highly-effective tool in many cases. In fact, many cardiologists routinely recommend stress...more
8/24/2021
/ Audits ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Documentation ,
False Billing ,
Health Care Providers ,
Investigations ,
Local Coverage Determinations (LCDs) ,
Medical Necessity ,
Medicare ,
Medicare Fraud ,
OIG ,
Policies and Procedures ,
Stress Tests
The tragedy of the COVID-19 pandemic is something we all agree we wish we could have avoided. However, the fact of the matter is that many respiratory and clinical labs have seen a boon to their bottom line due to the...more
8/10/2021
/ Chief Compliance Officers ,
Clinical Laboratories ,
Clinical Laboratory Testing ,
Compliance ,
Compliance Monitoring ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Infectious Diseases ,
OIG ,
Policies and Procedures ,
Regulatory Requirements ,
Virus Testing
Durable medical equipment (DME) is particularly important for many Medicare beneficiaries. However, companies that manufacture and sell DME need to be careful because there are strict federal regulations outlining almost...more
7/28/2021
/ Audits ,
Centers for Medicare & Medicaid Services (CMS) ,
Chief Compliance Officers ,
Civil Liability ,
Compliance ,
Compliance Commitees ,
Corrective Action Plans (CAPs) ,
Criminal Liability ,
Department of Health and Human Services (HHS) ,
Disciplinary Proceedings ,
Durable Medical Equipment ,
Employee Training ,
Health Care Providers ,
Healthcare Fraud ,
Medicaid ,
Medicare ,
OIG ,
Physicians ,
Policies and Procedures ,
Standard of Conduct ,
TRICARE
Clinical laboratories such as respiratory and clinical labs that bill Medicare, Department of Health and Human Services (“DHHS”) programs, and other federal programs are subject to oversight by the Office of Inspector General...more
7/14/2021
/ Chief Compliance Officers ,
Clinical Laboratories ,
Compliance ,
Compliance Commitees ,
Coronavirus/COVID-19 ,
Criminal Prosecution ,
Defense Strategies ,
Department of Justice (DOJ) ,
False Billing ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare Fraud ,
Indictments ,
Investigations ,
OIG ,
Policies and Procedures ,
Virus Testing
1. AML Laws -
Federal anti-money laundering (“AML”) laws are complex in nature and apply to a broad category of institutions and businesses. One of the most important AML laws is the Bank Secrecy Act, which obligates...more
5/18/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Broker-Dealer ,
BSA/AML ,
Compliance ,
Criminal Investigations ,
Criminal Prosecution ,
Customer Identification Program (CIP) ,
Defense Strategies ,
Due Diligence ,
Financial Institutions ,
Policies and Procedures ,
Popular ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
As federal agencies and law enforcement investigate pharmacies around the country for health care fraud and kickback schemes, pharmacies should be proactive in understanding their regulatory environment and the importance of...more
5/11/2021
/ Civil Liability ,
Compliance ,
Criminal Liability ,
Government Investigations ,
Healthcare Fraud ,
Kickbacks ,
Pharmaceutical Industry ,
Pharmacies ,
Policies and Procedures ,
Prescription Drugs ,
Regulatory Requirements
Companies of all sizes and in any industry would need effective corporate compliance programs. An effective compliance program not only mitigates risk in terms of reducing the likelihood of mistakes that can lead to...more
4/27/2021
/ Chief Compliance Officers ,
Compliance ,
Compliance Monitoring ,
Corporate Culture ,
Documentation ,
Employee Training ,
Enforcement ,
Internal Audit Functions ,
Internal Reporting ,
Investigations ,
Policies and Procedures ,
Risk Management ,
Risk Mitigation
The COVID-19 pandemic has created many new enforcement priorities for the U.S. Department of Justice (DOJ). From selling ineffective personal protective equipment (PPE) to companies fraudulently seeking loan forgiveness under...more
3/30/2021
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Controlled Substances ,
Controlled Substances Act ,
Coronavirus/COVID-19 ,
DEA ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Electronic Prescribing ,
Eliminating Kickbacks in Recovery Act of 2018 (EKRA) ,
FBI ,
Health Care Providers ,
Health Clinics ,
Healthcare Fraud ,
Medical Necessity ,
OIG ,
Opioid ,
Pharmaceutical Industry ,
Pharmacies ,
Physicians ,
Policies and Procedures ,
Prescription Drugs ,
Stark Law
The Office of Inspector General is a division of the U.S. Department of Health and Human Services that is tasked with combating fraud committed against Medicare, Medicaid, and other federally funded government programs. The...more
3/10/2021
/ Clinical Laboratories ,
Compliance ,
Compliance Monitoring ,
Corrective Action Plans (CAPs) ,
Dentists ,
Department of Health and Human Services (HHS) ,
Health Care Providers ,
Healthcare Facilities ,
Healthcare Fraud ,
Hospitals ,
Internal Audit Functions ,
Medicaid ,
Medical Billing Codes ,
Medicare ,
Nursing Homes ,
OIG ,
Pharmacies ,
Physicians ,
Policies and Procedures
What Is Corporate Intelligence?
Corporate intelligence is defined broadly as the process of acquiring business knowledge from internal and external sources in order to improve the productivity, sales, marketing, and...more
2/10/2021
/ Business Development ,
Business Operations ,
Complex Litigation ,
Compliance ,
Corporate Governance ,
Data Security ,
Due Diligence ,
Internal Controls ,
Internal Investigations ,
Policies and Procedures ,
Risk Assessment ,
Risk Management ,
Third-Party Risk
Compliance is a top legal concern for companies in all industries. From adequately protecting customer and employee data to avoiding allegations of bribery and fraud, compliance can mean different things under different...more
Most health care providers have at least a basic understanding of the Anti-Kickback Statute. This federal law prohibits providers from offering, paying, soliciting, or accepting any form of “remuneration” for patient...more
12/11/2020
/ Anti-Kickback Statute ,
Civil Liability ,
Clinical Laboratories ,
Criminal Liability ,
Criminal Penalties ,
Eliminating Kickbacks in Recovery Act of 2018 (EKRA) ,
False Claims Act (FCA) ,
Health Care Providers ,
Healthcare Facilities ,
Medicaid ,
Medicare ,
Medicare Part D ,
Noncompliance ,
Patient Referrals ,
Physicians ,
Policies and Procedures ,
Stark Law
Compliance is a key aspect of operating a successful pharmacy in the United States. This is true for pharmacies that bill federal healthcare benefit programs (i.e. Medicare, Medicaid, and Tricare) as well as private payors,...more
8/3/2020
/ Americans with Disabilities Act (ADA) ,
Cannabidiol (CBD) oil ,
Compliance ,
Controlled Substances Act ,
DEA ,
DSCSA ,
Federal Trade Commission (FTC) ,
GINA ,
Health Insurance ,
Medicaid ,
Medical Billing Codes ,
Medicare ,
Pharmacies ,
Pharmacist ,
Pharmacy Benefit Manager (PBM) ,
Policies and Procedures ,
Risk Mitigation ,
TRICARE
- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation.
- CEO leadership helps set an example for lower management and company...more
7/24/2020
/ Anti-Bribery ,
Anti-Corruption ,
CEOs ,
CFTC ,
Civil Monetary Penalty ,
Compliance ,
Corporate Counsel ,
Criminal Convictions ,
Criminal Investigations ,
Criminal Penalties ,
Department of Justice (DOJ) ,
Due Diligence ,
Duty to Preserve ,
Employee Training ,
Ethics ,
Failure to Comply ,
FBI ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Audit Functions ,
Leadership ,
Meals-Gifts-and Entertainment Rules ,
Policies and Procedures ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Tone At The Top