News & Analysis as of

Federal Pilot Programs

Presumption of Declination with Voluntary Disclosure, Cooperation, and Remediation of FCPA Violations

Deputy Attorney General Rod J. Rosenstein recently announced a revision to the U.S. Department of Justice (“DOJ”) policy on corporate enforcement of the Foreign Corrupt Practices Act (“FCPA”). The revision codifies a pilot...more

Property litigation update – pilot scheme launched for LTA 1954 unopposed lease renewals

by Dentons on

In January 2018 a one-year pilot scheme will be launched (postponed from 1 December 2017) for unopposed lease renewal proceedings issued at the County Court at Central London (CLCC). The scheme will transfer unopposed lease...more

2018 NDAA Analysis: Signals Towards the Federal Government’s Growing Interest in Blockchain Technology

by Holland & Knight LLP on

This is the seventh blog post in a series analyzing the current draft of the 2018 National Defense Authorization Act (NDAA) as signed into law on December 12, 2017. Stay tuned for more blog posts covering additional topics in...more

2017, We Hardly Knew You: A Look Ahead to 2018

by Holland & Knight LLP on

Taking over as editors of Holland & Knight’s Government Contracts Blog has been a labor, but it has been a labor of love. Like the rest of the Government Contracts Team, we are passionate about staying on top of the latest...more

Revisions To FCPA Enforcement Policies Still Pose Tough Questions For Honest Companies

by Fox Rothschild LLP on

In recent remarks, Deputy Attorney General Rod Rosenstein announced significant revisions to the Department of Justice’s (DOJ) policies for enforcing the Foreign Corrupt Practices Act. The policy revisions make permanent...more

FDA 2017 Year in Review: Refining Medical Device Pathways and Introducing Pilot Programs to Promote Quality

This is the third installment of our year-in-review series covering major developments at FDA.  While the previous two installments, pertain to FDA actions on drugs and biologics, this post will address developments related...more

Real-Time EMR Interface Program to Reduce Readmissions Finds Favor in OIG Advisory Opinion 17-07

by Baker Donelson on

A pilot program that could improve the efficacy of medication therapy management (MTM) services among Medicare Advantage (MA) beneficiaries would present minimal risk to federal health care programs and patients, according to...more

Real-Time EMR Interface Program to Reduce Readmissions Finds Favor in OIG Advisory Opinion 17-07

by Baker Ober Health Law on

A pilot program that could improve the efficacy of medication therapy management (MTM) services among Medicare Advantage (MA) beneficiaries would present minimal risk to federal health care programs and patients, according to...more

Hogan Lovells: ITC Section 337 Quarterly Highlights

by Hogan Lovells on

Will the 100 Day single issue program live up to its promise? When the ITC first ordered a Judge to take evidence on a single issue to determine if the issue was case dispositive, the year was 2013. After the order, the...more

OIG Advisory Opinion Allows Pilot Collaborative Program Proposed by Pharmaceutical Manufacturer for Medication Therapy Management...

On December 11, 2017, the Health and Human Services Office of Inspector General (OIG) posted a favorable Advisory Opinion, permitting a proposed pilot Program involving a collaboration between a pharmaceutical manufacturer...more

The Benefits of Corporate Anti-Corruption Programs: No Charges

by Blank Rome LLP on

The U.S. Department of Justice ("DOJ") and the Securities and Exchange Commission ("SEC") issued 15 declination letters in 2017 notifying companies of their decision not to pursue charges in connection with alleged violations...more

Happy Birthday FCPA: Implications of DOJ’s New FCPA Corporate Enforcement Policy on the Act’s 40th Anniversary

Today being the fortieth anniversary of the December 19, 1977 enactment of the Foreign Corrupt Practices Act (“FCPA”), we offer this Client Alert in celebration of the occasion. Fittingly, the U.S. Department of Justice...more

National Defense Authorization Act FY 2018: Directions In Federal Software Acquisitions

On December 12, 2017, President Trump signed the $700 billion 2018 National Defense Authorization Act (“NDAA”) into law. Following negotiations between the House and Senate Armed Services Committees, the NDAA includes new...more

FCPA in the Trump DOJ: Continuing Down the Same Path, with a Little More Heft

by Farella Braun + Martel LLP on

Next week marks the 40th anniversary of the Foreign Corrupt Practices Act – it became effective December 19, 1977. Deputy Attorney General Rod Rosenstein marked the occasion this month by providing an update on the FCPA Pilot...more

The DOJ’s Revised FCPA Corporate Enforcement Policy: A New Blueprint for Corporate Cooperation and Credit

by Williams Mullen on

On November 29, 2017, Deputy Attorney General Rod Rosenstein announced the issuance of a revised FCPA Corporate Enforcement Policy (the “Policy”). Rosenstein announced that the “new policy enables the Department [of Justice]...more

DOJ Incorporates FCPA Pilot Program into U.S. Attorneys' Manual Providing Permanent Incentives for Strong FCPA Compliance

by Blank Rome LLP on

Action Item: The U.S. Department of Justice (“DOJ”) recently included the principles of its Foreign Corrupt Practices Act (“FCPA”) Pilot Program into the U.S. Attorneys’ Manual (“USAM”), and reinforced its message to...more

100-Day Pilot Program Proceedings Remain Rare

by Jones Day on

In two recent orders, the Commission denied respondents’ requests for entry into its Early Disposition Pilot Program (100-day Pilot Program). It has now been over two years since the ITC issued its proposed rulemaking for the...more

The U.S. Justice Department’s Latest Compliance Program Warning

U.S Deputy Attorney General Rod Rosenstein recently announced the Department of Justice’s revised corporate enforcement policy for the Foreign Corrupt Practices Act. The revised policy is based on an FCPA pilot program (in...more

The Best Defense Is A Good Offense: FCPA Corporate Enforcement Policy Cements Importance Of Compliance Programs

The Department’s revised FCPA Corporate Enforcement Policy—which will be incorporated into the United States Attorneys’ Manual—builds on and makes permanent the Department’s 2016 FCPA Pilot Program....more

2018 NDAA Analysis: Intellectual Property Provisions

by Holland & Knight LLP on

This is the seventh blog post in a series analyzing the current draft of the 2018 National Defense Authorization Act (NDAA) as agreed to by House and Senate negotiators on November 8, 2017. Stay tuned for more blog posts...more

The DOJ’s Latest Compliance Program Warning

U.S Deputy Attorney General Rod Rosenstein recently announced the Department of Justice’s revised FCPA Corporate Enforcement Policy. The revised Policy is based on the DOJ’s FCPA Pilot Program (in place since April 2016),...more

Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy

by Michael Volkov on

The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function. The Justice Department and SEC’s FCPA...more

2018 NDAA Analysis: Acquisition Workforce Improvements

by Holland & Knight LLP on

This is the sixth blog post in a series of blogs analyzing the current draft of the 2018 National Defense Authorization Act (NDAA) as agreed-to by House and Senate negotiators on November 8, 2017. Stay tuned for additional...more

DOJ Issues New Policy Encouraging Self-Reporting FCPA Violations

by Bracewell LLP on

On November 29, 2017 the Deputy Attorney General of the U.S. Department of Justice (DOJ), Rod J. Rosenstein, announced a new FCPA enforcement policy that seeks to incentivize voluntary self-reporting by providing companies...more

This Week In Securities Litigation

by Dorsey & Whitney LLP on

The DOJ announced the formalization of a new FCPA cooperation policy built on the success of its Pilot Program. That program resulted in a significant increase in firm’s self-reporting and cooperating, the goal of the new...more

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