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Transparency Civil Monetary Penalty

Katten Muchin Rosenman LLP

Clearer Skies Ahead: CFTC Enforcement Division's New Advisory Opens Doors for Self-Reporting and Increased Cooperation

In what is being widely viewed as a welcome breath of fresh air, the Commodity Futures Trading Commission (the Commission or CFTC) Division of Enforcement (the Division) released an advisory on February 25, detailing the...more

Gardner Law

Sunshine Act Compliance: How to Take Action to Meet Reporting Requirements and Avoid Costly Penalties

Gardner Law on

The clock is ticking for medical device and pharmaceutical companies to fulfill their obligations under the Physician Payments Sunshine Act (the "Sunshine Act"). With the reporting deadline of March 31 looming and CMS...more

Gardner Law

OIG’s Perspective on Discount and Refund Programs

Gardner Law on

The U.S. Department of Health and Human Services Office of Inspector General (HHS OIG) recently issued Advisory Opinion No. 24-04, which primarily addressed a Refund Program offered by a U.S. pharmaceutical company affiliate....more

Carey Olsen

Cayman Islands investment funds – autumn 2024 update

Carey Olsen on

Our investment funds team outline the latest developments within the investment funds market in the Cayman Islands including the updated requirements under the Beneficial Ownership Transparency Act, a reminder of obligations...more

Cozen O'Connor

The EU AI Act: Part Four – Low Risk AI Systems and Enforcement

Cozen O'Connor on

This is part four of our examination of the European Union’s new artificial intelligence law, the (“EU AI Act”). In part one, we introduced the scope of the EU AI Act and discussed what types of AI systems are outright...more

Spilman Thomas & Battle, PLLC

The Health Record - Healthcare Law Insights, Issue 4, August 2024

Welcome to our fourth issue of The Health Record - our healthcare law insights e-newsletter. In this edition, we address a variety of topics including a recent SCOTUS ruling and the potential impact on CMS, issues of patient...more

Shipkevich PLLC

New Rule Issued by FTC Focuses on Fake and AI-Generated Reviews, Imposes Heavy Civil Penalties

Shipkevich PLLC on

The Federal Trade Commission (FTC) issued a new Final Rule (the “Rule”) on Wednesday, August 14, 2024, targeting unfair and deceptive acts or practices specifically related to consumer reviews and testimonials, allowing the...more

Gardner Law

CMS Audits on the Horizon: Prepare for Increased CMS Audits Under the Sunshine Act

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Historically, the Centers for Medicare and Medicaid Services (“CMS”) has not aggressively pursued enforcement activity under the Sunshine Act. However, this may change in 2024. Late last year, CMS updated its Open Payments...more

King & Spalding

Federal District Court in Alabama Declares CTA Unconstitutional; DOJ Appeals to 11th Circuit; FinCEN Requires Continued Compliance

King & Spalding on

On March 1, 2024, a federal judge in the U.S. District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (“CTA”) is unconstitutional. The CTA and its implementing regulations require that...more

Adams & Reese

CTA Update – Where Do We Stand After Alabama District Court Ruling?

Adams & Reese on

On March 1, 2024, the Northern District of Alabama Northeastern Division, in National Small Business United v. Yellen, No. 5:22-cv-1448 (N.D. Ala.), ruled the Corporate Transparency Act unconstitutional. However, the holding...more

McNees Wallace & Nurick LLC

CTA Here to Stay? Federal District Court Rules Corporate Transparency Act Unconstitutional

Although the Corporate Transparency Act (“CTA”) became effective Jan. 1, 2024, in just two short months, its constitutionality was challenged in the U.S. District Court, Northern District of Alabama’s decision issued on March...more

Kohrman Jackson & Krantz LLP

Federal District Court in Alabama Deems Corporate Transparency Act Unconstitutional

The Corporate Transparency Act (the CTA), which became effective on January 1, 2024, was ruled unconstitutional by the U.S. District Court for the Northern District of Alabama (District Court), in the case styled National...more

ArentFox Schiff

CMS Proposed Rule for Minimum Staffing Requirements in Long-Term Care Facilities

ArentFox Schiff on

On September 1, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule titled “Minimum Staffing Standards for Long-Term Care (LTC) Facilities and Medicaid Institutional Payment Transparency...more

Davis Wright Tremaine LLP

Swaps Enforcement Update: Business Conduct Standards for Swap Dealers and Major Swap Participants

While the initial swap dealer enforcement actions brought by the Commodity Futures Trading Commission (CFTC) focused on swap data reporting failures, recent enforcement efforts have focused on compliance with business conduct...more

McGuireWoods Consulting

CMS Tightens Hospital Price Transparency Enforcement Measures

On April 26, the Centers for Medicare and Medicaid Services (CMS) strengthened its enforcement of the hospital price transparency rule by implementing three new enforcement measures. These include...more

Bass, Berry & Sims PLC

Major Campaign Finance and Ethics Reform Bill: What PACs & Non-Profits Need to Know on July 1

Bass, Berry & Sims PLC on

The 112th General Assembly adjourned sine die on April 28th, 2022, but many of the successful measures will become effective on July 1st. Public Chapter 1087 – one of the most weighty and intricate bills – made changes to...more

Lowenstein Sandler LLP

The FTC Actively Enforcing Truthful Review and Endorsement Practices

Lowenstein Sandler LLP on

Third-Party Review Services are a Focus- On January 25, the Federal Trade Commission announced that Fashion Nova LLC will be prohibited from suppressing customer reviews of its products and required to pay $4.2 million to...more

Steptoe & Johnson PLLC

CMS Continues Its Focus on Hospital Pricing Transparency

The Centers for Medicare & Medicaid Services’ (“CMS”) message this year has been consistent – hospitals need to comply with CMS’ Hospital Transparency Rule. This rule requires hospitals and health systems to disclose a...more

Groom Law Group, Chartered

Trump Administration Issues COVID-19 Vaccine and Transparency Rules

In late October, the Trump Administration, through the Departments of Health and Human Services (“HHS”), the Treasury, and Labor (“Departments”), issued two different rules — one implementing the Coronavirus Aid, Relief, and...more

Society of Corporate Compliance and Ethics...

Food supply chains under increasing scrutiny

Report on Supply Chain Compliance 2, no. 20 (Oct. 24, 2019) - The United States Federal Trade Commission (FTC) issued a monetary penalty for “greenwashing” last month, the first such penalty imposed on a company for falsely...more

Sheppard Mullin Richter & Hampton LLP

Years in the Making: The Health Resources & Services Administration Launches a Website to Increase Pricing Transparency in the...

If you overheard Medicaid providers breathe audible sighs of relief on April Fool’s Day, it may be because on April 1, 2019, the Health Resources & Services Administration of the Department of Health and Human Services...more

Morgan Lewis

CFTC Proposes Amendments to Whistleblower Awards Process and Anti-Retaliation Authority

Morgan Lewis on

The amendments would make the CFTC’s whistleblower awards process more uniform with the SEC’s program and would enable the CFTC to bring enforcement actions against employers that retaliate against whistleblowers....more

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