False Claims Act: Implied Certification Theory
The United States Environmental Protection Agency (“EPA”) and Heritage Training and Shooting Center, LLC (“Heritage”) entered into a January 6th Expedited Settlement Agreement (“ESA”) addressing alleged violations of the...more
You have to wonder how OFAC has the time to investigate and settle cases given its significant work implementing the Russia Sanctions Program. But OFAC continues to demonstrate its commitment to aggressive enforcement. ...more
Earlier this month, it was announced that Honeywell International, Inc. (Honeywell) had entered into a $13 million administrative settlement with the U.S. government to resolve allegations of export control violations related...more
UniControl, Inc., a Cleveland, Ohio manufacturer of process controls, airflow pressure switches, boiler controls and other instruments, agreed to pay OFAC $216,464 to settle its liabilities for violation of the Iran Sanctions...more
After an ill-fated multi-year effort to develop a self-driving car, Uber (which spent “hundreds of millions of dollars” on the project) is “handing the autonomous vehicle effort over to a Silicon Valley start-up”—Aurora—along...more
Government contractors are no strangers to the numerous quality standards and assurances required by the government. Over the past several years, cybersecurity in federal contracting has emerged as yet another standard to...more
On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more
I thought Frosty was a good analogy to consider the disgraced Goldman Sachs Group Inc.’s former partner Tim Leissner, as he is certainly back again. Yesterday, I begin a two-part blog post series on Leissner’s settlement with...more
As reported by Byron Tau and Aruna Viswanatha in the Wall Street Journal (WSJ), “Jho Low, the businessman-turned-fugitive accused of masterminding a multibillion-dollar fraud involving Malaysia’s sovereign-wealth fund, agreed...more
In its second quarter Securities Exchange Commission (SEC) filing, Allscripts addressed its announced agreement in principle with the Department of Justice (DOJ) to resolve investigations into certain alleged practices of...more
As the old adage provides – better late than never. (Same applies for my somewhat tardy posting on this case). Telefônica Brasil settled FCPA violations with the SEC for a pretty penny — $4.125 million in civil penalties...more
In a murderer’s row of what not to do as a mortgage creditor, the 11th Circuit recently reversed summary judgment in favor of a creditor for alleged violations of the Fair Credit Reporting Act (“FCRA”), Florida Consumer...more
The Justice Department and the Treasury Department’s Office of Foreign Asset Control (OFAC) are on a roll. Global banks are facing renewed prosecutions, along with aggressive sanctions prosecutions of companies for...more
A payment processor and its individual owner have entered into a settlement with the FTC to settle charges that they violated a 2009 federal district court order that required them to review and monitor their merchant clients...more
Global banks are the poster children of sanctions violations and the importance of trade compliance. At the top of the heap is Standard Chartered Bank....more
What a difference a year makes — The Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced two sanctions settlements in the beginning of 2019, a stark difference from 2018 when OFAC announced its first...more
On December 5, 2018, the Minnesota-based Target Corp. store chain settled with a coalition of California governmental entities for $7.4 million, which included enhanced environmental compliance measures and injunctive...more
In the wake of the determination by the European Commission that the EU-US Safe Harbor Framework was insufficient to protect EU citizens’ personal information, the Privacy Shield Framework was implemented by the Department of...more
The United States Environmental Protection Agency (“EPA”) entered into an Expedited Settlement Agreement (“ESA”) with First Group America, Inc., d/b/a First Student, Inc. and First Transit, Inc. See Docket No....more