CFPB's Policy Statement on Abusiveness (Part 2) - The Consumer Finance Podcast
Compliance Perspectives: Changes to the Physician Self-Referral and Anti-Kickback Rules
The UK’s Financial Conduct Authority (“FCA”) and Prudential Regulation Authority (“PRA”) have issued a joint policy statement on their guidelines for the prudential assessment of acquisitions and increases in qualifying...more
According to a recent policy statement issued by the Consumer Financial Protection Bureau (the CFPB), employers that purchase or use certain reports generated about current or prospective employees—including those using...more
purred by increased online and mobile app shopping during the COVID-19 pandemic, the Buy Now, Pay Later (BNPL) market has experienced higher growth and popularity as an innovative consumer finance offering, particularly for...more
If your enterprise doesn’t yet have a policy, it needs one. We explain here why having a governance policy is a best practice and the key issues that policy should address....more
Be you a merger and acquisition attorney, corporate compliance officer, or counsel to an acquiring entity or target entity, you should review the Department of Justice’s new Merger and Acquisition Safe Harbor Policy...more
On October 4, 2023, United States Deputy Attorney General (DAG) Lisa Monaco announced a new Department of Justice (DOJ) Mergers & Acquisitions Safe Harbor policy that encourages companies to self-disclose criminal misconduct...more
The U.S. maritime industry is steeped in tradition and sometimes takes a conservative approach to change. Even when the industry has protocols in place to ensure safety of mariners, in some cases it takes an act of...more
Compliance assessments can be a valuable tool during the mergers and acquisitions process, but the Department of Justice (DOJ) is incentivizing due diligence reviews under a newly announced policy. Deputy Attorney...more
Continuing its focus on incentivizing prompt and voluntary self-disclosure of criminal misconduct, Deputy Attorney General Lisa Monaco announced earlier this month a new U.S. Department of Justice (DOJ) Safe Harbor Policy...more
The U.S. Department of Justice (DOJ) is offering more lenient treatment to companies that voluntarily self-disclose misconduct of a company being acquired that comes to light during a mergers and acquisitions (M&A)...more
The United States Department of Justice (DOJ) recently announced a new department-wide Mergers & Acquisitions Safe Harbor Policy that protects acquiring companies that self-disclose criminal misconduct discovered at an...more
The policy expands upon DOJ’s efforts to encourage self-reporting of criminal violations discovered during M&A and other transactions. On October 4, 2023, US Deputy Attorney General Lisa Monaco announced a new Department...more
In an important policy announcement aimed at rewarding robust due diligence and compliance programs, DOJ announced that acquiring companies that promptly and voluntarily disclose criminal misconduct discovered at the acquired...more
Deputy Attorney General Lisa Monaco announced a new safe harbor policy for voluntary self-disclosures made in connection with mergers and acquisitions on Wednesday. Pursuant to this new policy, the DOJ will not prosecute...more
Over the last two years, the Department of Justice (DOJ) has announced numerous policy changes on corporate criminal enforcement policies, which were largely based on a self-described “carrot and sticks” approach (“a mix of...more
Department of Justice Withdraws Long-Standing Antitrust Healthcare Policy Statements - On February 2, 2023, the Antitrust Division of the US Department of Justice (DOJ) announced the withdrawal of its support for three...more
On April 18, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) Office of Export Enforcement (“OEE”) released a set of “policy clarifications” in the context of a memorandum authored by the...more
As winter starts to recede, thoughts turn to warmer days and the need to embark on the traditional spring cleaning. While that’s usually an at-home affair, it can and should also apply to your compliance program. And while a...more
On 3 August 2022, the UK’s Financial Conduct Authority (“FCA”) published a policy statement (PS22/11) on improvements to the appointed representatives (“ARs”) regime. The FCA consulted on amendments to the AR framework in...more
On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more
On October 28, 2021, Deputy Attorney General (Deputy AG) Lisa O. Monaco gave remarks explicitly warning companies that the US Department of Justice (DOJ) intends to increase its efforts and devote additional resources to...more
The changes include more focus on individual accountability, more holistic evaluation of prior corporate misconduct, and stricter corporate resolutions. On October 28, 2021, US Deputy Attorney General Lisa Monaco gave the...more
Following the new Export Control Law of China that encourages all exporters to establish an internal compliance program, China’s Ministry of Commerce (MOFCOM) has published guidelines for the internal compliance programs of...more
Bradley’s Environmental Law team has for years taken on the duty of helping our clients protect themselves and the environment by taking a proactive stand to keep their businesses in order. The best defense to an...more
As healthcare moves increasingly from fee-for-service model to one focused on outcomes and value-based payments, the traditional fraud and abuse laws, such as the Anti-Kickback Statute and the Stark Law, pose obstacles to...more