News & Analysis as of

Third-Party Service Provider Department of Justice (DOJ)

Goodwin

DOJ’s Data Export Rule Is In Force April 8: What You Need to Do

Goodwin on

On April 8, 2025, a sweeping rule issued by the US Department of Justice (DOJ) will take effect. The rule imposes restrictions—and in some cases, outright prohibitions—on US companies in connection with certain types of data...more

BakerHostetler

DOJ and FTC Withdraw Antitrust Competitor Collaboration Guidelines

BakerHostetler on

The US Department of Justice (“DOJ”) and the Federal Trade Commission (“FTC”) announced on Wednesday the withdrawal of the Antitrust Guidelines for Collaborations Among Competitors originally issued in 2000....more

Holland & Knight LLP

DOJ Scrutinizes Financial Arrangements of Florida Physician Practice

Holland & Knight LLP on

The U.S. Department of Justice (DOJ) announced in a Nov. 12, 2024, press release that an ophthalmology practice with offices located in West Central Florida (the Provider) entered into an approximately $1.3 million settlement...more

A&O Shearman

DOJ Cracks Down on Third Party Information Benchmarking

A&O Shearman on

On September 28, 2023, the Department of Justice (DOJ) launched a civil suit against a benchmarking service provider that signals a crack-down on benchmarking involving the exchange of competitively sensitive information. ...more

Foley & Lardner LLP

DOJ Withdraws Policy Statements That Defined Limited Safe Harbor for Information Sharing Among Competitors

Foley & Lardner LLP on

On February 3, 2023, the U.S. Department of Justice’s Antitrust Division (DOJ) announced that it is withdrawing three policy statements the DOJ and Federal Trade Commission (FTC) issued between 1993 and 2011, related to...more

HaystackID

[Webcast Transcript] eDiscovery Playbooks: How to Win by Day and Sleep at Night

HaystackID on

Editor’s Note: On September 21, 2022, Business Intelligence Associates (BIA), a recently acquired HaystackID company, shared an educational webcast on the role of eDiscovery playbooks in litigation preparedness. Regardless of...more

Seward & Kissel LLP

DOJ’s Revised Corporate Criminal Enforcement Policies Encourage Voluntary Disclosure and Focus on Compensation

Seward & Kissel LLP on

On September 15, 2022, Deputy Attorney General Lisa O. Monaco announced new Department of Justice (“DOJ”) policies on corporate criminal enforcement. DOJ designed the new policies based on recommendations by the Corporate...more

Williams Mullen

DOJ Policy Restores Settlement Agreements Involving Payments to Non-Governmental Third Parties

Williams Mullen on

Settlement agreements regarding payments to non-governmental third parties were sharply curtailed by the Trump administration. A recent DOJ policy and rulemaking restores the authority for DOJ to enter into settlements...more

The Volkov Law Group

SAP’s Comprehensive Export Control and Sanctions Settlement – A New Compliance Frontier for Cloud-Based Services (Part III of IV)

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The Justice Department’s National Security Division used the SAP comprehensive settlement of export control and sanctions violations to send a message – a loud and clear one....more

Thomas Fox - Compliance Evangelist

Compliance Responses to Bribery Schemes

Yesterday, I looked at some of the more creative bribery schemes identified in 2019 Foreign Corrupt Practices Act (FCPA) enforcement actions. They were schemes involving distributors, joint ventures (JVs) and fraudulent...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action - Part 4: The Double Whammy in Penalties

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 3: Internal Control Failures

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

WilmerHale

DOJ Issues Updated Guidance on Evaluation of Corporate Compliance Programs

WilmerHale on

On April 30, 2019, the Assistant Attorney General for the Criminal Division, Brian A. Benczkowski, announced an update to the Department of Justice’s (“DOJ”) 2017 guidance document entitled Evaluation of Corporate Compliance...more

Mintz - Health Care Viewpoints

A Tale of Two False Claims Act Settlements Involving EHR Vendors

Last week the Department of Justice (DOJ) announced a $57 million settlement with electronic health record (EHR) software vendor Greenway Health LLC (Greenway). According to DOJ, Greenway violated the False Claims Act (FCA)...more

Goodwin

Financial Services Weekly News - September 2017 #3

Goodwin on

Editor's Note - Cybersecurity Returns to Center Stage. The Equifax breach and recent news that the Securities and Exchange Commission’s (SEC) EDGAR test filing system was hacked in 2016 have brought cybersecurity back to...more

Jones Day

"Meaningfully Useful" Risk Mitigation Strategies for Providers Following the eClinicalWorks Settlement

Jones Day on

The Health Information Technology for Economic and Clinical Health Act ("HITECH Act") established financial incentives under Medicare and Medicaid for eligible health care providers that adopt, implement, and demonstrate use...more

Downey Brand LLP

DOJ Issues Policy Memo Limiting the Use of Supplemental Environmental Projects in Federal Settlements

Downey Brand LLP on

On June 7, 2017, the United States Department of Justice (DOJ) issued a policy memorandum dated June 5, 2017 that prohibits the allocation of settlement funds to non-governmental, third-party organizations, as a condition of...more

Bass, Berry & Sims PLC

A Striking EHR Settlement: The DOJ pursues an EHR Vendor for "Causing the Submission" of False EHR Incentive Payment Claims

On May 31, 2017, the U.S. Department of Justice (DOJ) announced a $155 million settlement with eClinical Works (ECW), a nationally-known electronic health records (EHR) software vendor. The settlement arises out of a lawsuit,...more

NAVEX

Third-Party Risk Programs Should Focus on Offense, not Defense

NAVEX on

Just 43 percent of organizations surveyed in NAVEX Global’s 2016 Ethics & Compliance Third Party Risk Management Report said they evaluated third parties before engaging with them—down from 68 percent in 2015....more

Stinson LLP

Emerging Trends Newsletter - Q3

Stinson LLP on

We are thrilled to bring you the third installment of Stinson Leonard Street's Emerging Trends newsletter. We are proud of the depth and breadth of experience and knowledge across our firm's 13 offices nationwide and are...more

Perkins Coie

SEC’s Increased Cybersecurity Enforcement and How to Reduce Your Risks

Perkins Coie on

The SEC announced last week that an investment adviser had agreed to settle charges that it failed to take required steps to protect against and respond effectively to a cybersecurity breach. The action comes on the heels of...more

King & Spalding

Unprecedented Hacking and Trading Scheme Highlights Key Cybersecurity Lessons

King & Spalding on

On Aug. 11, 2015, federal prosecutors in the District of New Jersey and the Eastern District of New York unsealed indictments against nine individuals in the U.S. and Ukraine who were allegedly involved in a five-year,...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA

In this episode I discuss the training of third parties under the FCPA. I review the DOJ/SEC FCPA Guidance on this issue; the risk ranking of third parties to help deliver your training; the types of training you can utilize...more

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