News & Analysis as of

Due Diligence Civil Monetary Penalty

Health Care Compliance Association (HCCA)

Due diligence and physician financial arrangements

Conducting due diligence for physician and provider compensation arrangements during a healthcare transaction is critical for the acquirer. Appropriate due diligence is necessary, regardless of whether the transaction is a...more

Dechert LLP

Third Circuit Holds Securitization Trusts Are “Covered Persons” Under CFPA

Dechert LLP on

A long-awaited Third Circuit decision held that securitization trusts holding student loans are “covered persons” subject to the CFPB’s enforcement and investigative powers because they “engage” in offering or providing...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

Seward & Kissel LLP on

The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

Gardner Law

Healthcare Enforcement in a Post-Pandemic World

Gardner Law on

After a year-over-year reduction in drug, device, and biologic Warning Letters from 2012 through 2019, Warning Letters spiked to pre-2014 levels in 2020 during the pandemic. This was due in large part to a significant number...more

White & Case LLP

Supply Chain Compliance with Human Rights and Environmental Obligations

White & Case LLP on

The United States, the European Union, and Germany have recently adopted or proposed new rules requiring enhanced due diligence in supply chains, targeting human rights and environmental issues. This alert examines key...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update – FinCEN Issues Notice of Proposed Rulemaking

On December 15, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (the “NPRM”) that would implement provisions of the Corporate Transparency Act (the “CTA”) regarding access to...more

Lerman Senter PLLC

FCC Enforcement of Sponsorship Identification Rules

Lerman Senter PLLC on

In a recent decision, the FCC’s Media Bureau entered into a consent decree with the licensee of a low-power TV station that violated the sponsorship identification rules. The station paid a civil penalty of $60,000 and agreed...more

WilmerHale

OFAC Enforcement Actions Highlight Risks to Software Providers & MSBs

WilmerHale on

On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments For March 2021

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Oberheiden P.C.

A CEO's Guide to FCPA Compliance

Oberheiden P.C. on

- 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

Latham & Watkins LLP

Gesetzentwurf zur Bekämpfung der Unternehmenskriminalität bringt neue Regeln für interne Untersuchungen – Datenschutz gewinnt...

Latham & Watkins LLP on

Das Justizministerium arbeitet mit Hochdruck an einem Entwurf für ein Unternehmensstrafrecht. Der Entwurf verfolgt das Ziel, die Sanktionierung von Unternehmen und sonstigen Verbänden auf eine eigene gesetzliche Grundlage zu...more

Dechert LLP

FCA Enforcement Risk: The Year Ahead

Dechert LLP on

Firms will need to ensure their systems and controls to prevent financial crime and money laundering are working effectively: this is just part of the message contained in the FCA’s Business Plan for 2019/20. The Business...more

Akin Gump Strauss Hauer & Feld LLP

United States Intervenes in Suit Against Private Equity Firm Based on Health Care Portfolio Company's Alleged False Claims Act...

• In an unusual move, the government has decided to pursue a False Claims Act (FCA) suit against a private equity firm based on an alleged commission scheme at its pharmacy portfolio company to promote sales of products...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

Dechert LLP

FCPA Enforcement Action Highlights Risks for the Financial Services Industry and Individual Executives

Dechert LLP on

New York-based hedge fund Och-Ziff Capital Management Group (the “Hedge Fund”) agreed to pay approximately $412 million to resolve charges brought by the U.S. Securities and Exchange Commission (“SEC”) and Department of...more

Burr & Forman

SEC Affirms Sanctions on Stanford’s CCO

Burr & Forman on

The SEC recently affirmed its ALJ’s ruling barring Alan Stanford’s former CCO from the industry and ordering monetary penalties of $260,000 together with $591,992 in disgorgement. The Commission held the CCO approved false...more

Epstein Becker & Green

Illegal Premerger Coordination Leads to DOJ “Gun Jumping” Enforcement Action and $5 Million Settlement—Key Lessons Affecting...

On November 7, 2014, the Antitrust Division of the U.S. Department of Justice (“DOJ”) reached a $5 million settlement with Flakeboard America Limited (“Flakeboard”), its foreign parents, and SierraPine to settle allegations...more

Akin Gump Strauss Hauer & Feld LLP

Antitrust-Related Recent Developments: DOJ settles gun-jumping case, FTC issues fines for failure to submit HSR filing and FTC...

DOJ fines particleboard manufacturers $4.95 million for gun-jumping violations - On Friday, November 7, 2014, two companies agreed to pay $4.95 million to settle U.S. Department of Justice (DOJ) allegations that the...more

Skadden, Arps, Slate, Meagher & Flom LLP

"DOJ Antitrust Action Condemns Pre-Merger Coordination Requiring Target Company to Sell Factory"

On November 7, 2014, the United States Department of Justice, Antitrust Division (DOJ) announced a $5 million agreement to settle charges that Flakeboard and SierraPine had engaged in unlawful pre-merger coordination. The...more

Proskauer Rose LLP

Five Million Dollar Penalty is Stark Reminder About "Gun Jumping"

Proskauer Rose LLP on

On November 7, 2014, the Antitrust Division of the Department of Justice ("DOJ") announced that it had imposed a civil penalty of $3.8M and disgorgement of $1.15M in profits on Flakeboard America Limited (and its parent...more

Goodwin

OCC and FinCEN Take Enforcement Actions and Assess Civil Money Penalty Against Small Bank for BSA/AML Violations

Goodwin on

The OCC entered into a consent order with a small, New Jersey-based bank with approximately $118 million in total assets for violations of the Bank Secrecy Act (the “BSA”). The OCC assessed a civil money penalty (“CMP”)...more

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