The Briefing: Failure to Disclose Relationship with Real Party in Interest Results in Serious Sanctions
Podcast: The Briefing - Failure to Disclose Relationship with Real Party in Interest Results in Serious Sanctions
In recent months, NIH signaled that it, in the words of Director Monica Bertagnolli, understands the “difficult climate for our valued Asian American, Asian immigrant and Asian research colleagues who may feel targeted and...more
In the ever-evolving compliance landscape, the recent enforcement action by the Securities and Exchange Commission (SEC) against RR Donnelley is a significant case study. This incident underscores the importance of robust...more
The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more
The recent SEC lawsuit against SolarWinds Corp and its CISO, Tim Brown, following the 2020 data breach, has brought the issue of executive liability in cybersecurity disclosures to the forefront. This case sheds light on the...more
Report on Research Compliance 20, no. 11 (November, 2023) It wasn't just China. China is among the countries whose support for Stanford University investigators wasn’t reported to five federal research funding agencies,...more
Ericsson’s breach of its 2019 Deferred Prosecution Agreement reads like an internal investigation horror show. It is every investigator’s nightmare scenario – failure to discover evidence that was available to inform and...more
After more than 10 years of litigation and a four-week bench trial, a District Court in D.C. recently found a contractor liable under the False Claims Act (FCA) in connection with the U.S. General Services Administration’s...more
As one of the most famous individuals in the world, it is not uncommon for Kim Kardashian (“Kardashian”) to make headlines. Recently, the headline related to fines and penalties to be paid to the Securities and Exchange...more
On June 30, 2022 the Securities and Exchange Commission (SEC) brought a settled enforcement case against a Chief Compliance Officer (CCO) and a Registered Investment Adviser (RIA). At first glance, the case appears...more
Report on Research Compliance 18, no. 7 (July 2021) - In a review of more than 500 NIH awards, the HHS Office of Inspector General (OIG) found that about one-fifth were funded “out of rank order,” and for more than a...more
Federal prosecutors take an oath to execute their duties faithfully. Yet, like all professions, some federal prosecutors have violated this oath. For years, prosecutorial misconduct has come under heightened scrutiny. Do not...more
The internal controls provision in the FCPA statute has broad application to a variety of situations beyond foreign bribery. The Securities and Exchange Commission knows full well the power of the internal controls provision...more
Report on Medicare Compliance 29, no. 5 (February 10, 2020) - David Laufer, the former chief of the Prosthetics and Orthotics Department at Walter Reed National Military Medical Center in Bethesda, Maryland, was charged...more
Report on Research Compliance 17, no. 2 (January 23, 2020) - Acting with “deliberate ignorance” and “reckless disregard” are not words that any institution wants to hear associated with its name. But these are at the heart...more
From Elon Musk’s tweets to Floyd Mayweather and DJ Khaled’s promotion of cryptocurrencies, 2018 was, to say the least, an interesting year in regulatory enforcement news. Even if all you do is win, win, win, no matter what,...more
On August 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert providing a summary of the staff’s observations from sweep exams of broker-dealers, investment advisers and funds...more
Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more