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Compliance White Collar Crimes False Claims Act (FCA)

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Enters First Intervention in Cybersecurity Qui Tam

The U.S. government’s recent complaint in a relator-filed case under the False Claims Act (FCA): - Marks the first FCA suit in which the Department of Justice (DOJ) has intervened since launching its ongoing Civil...more

K&L Gates LLP

The False Claims Act and Health Care: 2023 Recoveries and 2024 Outlook

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On 22 February 2024, the US Department of Justice (DOJ) published the statistics for federal civil fraud recoveries in Fiscal Year (FY) 2023. The DOJ announced that the “government and whistleblowers were party to 543...more

Husch Blackwell LLP

Let’s Make a Deal with DOJ: The Impact of the DOJ’s New Whistleblower Reward Program on Corporate Compliance

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While Monty Hall (or for the current generation, Wayne Brady) was nowhere in sight, it was difficult not to think about the show “Let’s Make a Deal” while sitting in the audience at the American Bar Association’s 39th...more

Dentons

Ep. 12 - Working with Valuation Experts to Substantiate Fair Market Value Compensation

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We often work with valuation experts to ensure compensation payments between healthcare organizations and physicians are fair market value and commercially reasonable for purposes of compliance with the Stark Law and the...more

ArentFox Schiff

Investigations Newsletter: Deputy Attorney General Monaco Warns Industries: “Fraud Using AI is Still Fraud”

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On March 7, Deputy Attorney General Lisa Monaco delivered the keynote remarks at the American Bar Association’s (ABA) 39th National Institute on White Collar Crime. She noted that artificial intelligence (AI) “holds great...more

Wiley Rein LLP

DOJ to Use ‘Carrots to Wield Larger Sticks’ in 2024

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The more things change, the more things stay the same. For years, U.S. Department of Justice (DOJ) leadership has used the ABA National Institute on White Collar Crime and other major conferences to highlight enforcement...more

Mintz

EnforceMintz — DOJ’s Efforts in 2023 to Incentivize Voluntary Self-Disclosure

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2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more

Torres Trade Law, PLLC

Trade Violations Under the False Claims Act

On February 7, the U.S. Department of Justice (DOJ) announced that settlements and judgements under the False Claims Act (FCA) exceeded $2 billion for the 2022 fiscal year. The 2022 fiscal year also had the second-highest...more

Womble Bond Dickinson

Current Trends and Real-World Best Practices in Healthcare Fraud Compliance

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Recently, Womble Bond Dickinson held its First Annual Health Care Fraud Symposium, a webinar designed to discuss critical healthcare fraud topics. WBD Partner Joe Whitley moderated a discussion with WBD attorneys Luke Cass,...more

Kaufman & Canoles

Special Fraud Alert Released by OIG Following Nationwide Arrest of Dozens Accused in Telehealth Scams

Kaufman & Canoles on

On July 20, 2022, the Department of Justice announced charges against 36 criminal defendants across 13 different federal districts for healthcare fraud violations resulting in Government losses in excess of $1.2 billion. The...more

WilmerHale

A Look Ahead into Corporate Enforcement in the Biden Administration

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Just one year after President Biden’s election, senior administration officials have signaled in public remarks that the federal government will amplify enforcement pressure on corporations and their employees through...more

White & Case LLP

More Aggressive White Collar Enforcement Expected Under the Biden Administration

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The first 100 days of President Biden's administration, not least its appointments to key leadership positions, suggest that it will investigate and pursue white collar cases much more aggressively than the Trump...more

Proskauer - The Capital Commitment

Return to Civil and Criminal Collaboration in White Collar under Biden Administration

Under the Biden Administration, we expect the Department of Justice to reinvigorate the policies aimed at increasing coordination between the criminal and civil divisions. In a 2015 Memorandum – the “Yates Memo” – former...more

Kohn, Kohn & Colapinto LLP

Congress Needs to Enact an Effective Ethics Agenda

Congress needs to implement an effective ethics agenda.  Important anti-corruption legislation has been sitting in various Senate and House committees awaiting action....more

The Volkov Law Group

Cancer Treatment Center Agrees to DPA and $100 Million Penalty for Criminal Antitrust Violations in Florida Market

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The Justice Department’s Antitrust Division recently announced a $100 million settlement with Florida Cancer Specialists & Research Institute (“FCS”) for an illegal conspiracy to allocate cancer patients in Southwest...more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Healthcare Fraud Trends in 2020

Editors’ Note: This is the second in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed SEC enforcement in 2020. Up next: a look at...more

White & Case LLP

President Trump's trade wars and the expansion of customs violations into the white-collar space

White & Case LLP on

The US' ongoing trade wars—with various trading partners and particularly with China—are everywhere in the news. Putting politics and policy aside, the "trade wars" reflect a basic disagreement over the rules that should...more

The Volkov Law Group

Avanir Pharmaceuticals Pays More than $108 Million to Settle Kickback Violations

The Volkov Law Group on

Just to repeat myself – pharmaceutical and medical device firms face extraordinary risks of enforcement under the False Claims Act.  While everyone likes to write and focus on FCPA or anti-corruption risks for global drug and...more

Akin Gump Strauss Hauer & Feld LLP

[Podcast] DOJ’s New Guidance on Evaluating Compliance Programs: What You Need to Know

In this episode, Akin Gump health care and life sciences counsel Taylor Jones and Matt Wetzel discuss the Justice Department’s recent guidance on evaluation of corporate compliance programs. Among the topics covered: •...more

Polsinelli

DOJ Implements Formal Policies for Cooperation Credit in False Claims Act Cases

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Last month, Polsinelli highlighted a recent update to the Department of Justice (DOJ) Evaluation of Corporate Compliance Programs, which detailed how DOJ will evaluate the effectiveness of corporate compliance programs in the...more

The Volkov Law Group

Three Pharmaceutical Companies Pay a Total of $122 Million to Settle Kickback Allegations Involving Co-Pay Assistance Foundations

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In a significant False Claims Act enforcement action, DOJ announced settlements with three pharmaceutical companies – Jazz Pharmaceuticals, Lundbeck, and Alexion Pharmaceuticals – under which they agreed to pay $122 million...more

Parker Poe Adams & Bernstein LLP

What Businesses Need to Know About Government Investigations in 2019

The U.S. Justice Department (DOJ) is still in the early days of applying a significant change to how companies get credit for cooperating during government investigations. In a speech delivered on November 29, 2018, Deputy...more

The Volkov Law Group

Hospitals and Physician Relationships – Navigating Stark, AKS and Fraud Risks (Part III of III)

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Chief compliance officers at hospitals face a crushing burden of risks. The HHS-OIG has vigorously scrutinized hospitals compensation of physicians, especially for potential anti-kickback and Stark law violations. Most of...more

Blank Rome LLP

White Collar Watch (December 2018 • No. 3)

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NOTE FROM THE EDITORS - All of us here at Blank Rome wish you and yours a happy and healthy holiday season and start to 2019. We are pleased to present our final 2018 edition of White Collar Watch, which includes timely...more

Foley & Lardner LLP

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

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Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

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