The Department of Justice (“DOJ”) recently announced its largest ever health care fraud and opioid enforcement action. In a coordinated effort, DOJ charged 345 defendants with more than $6 billion in fraud losses for submitting false and fraudulent claims to federal health care programs and private insurers.… Continue Reading
The Second Circuit’s recent decision in United States v. Hoskins may impact enforcement of U.S. economic sanctions programs. The Hoskins decision precludes the government from charging a foreign national acting abroad with violating the Foreign Corrupt Practices Act (“FCPA”) through theories of conspiracy and accomplice liability. This holding is equally applicable to U.S. sanctions law.… Continue Reading
In remarks at NYU’s Program on Corporate Compliance and Enforcement, Steven Peikin, the new Co-Director of the SEC’s Enforcement Division, voiced a question that has been on the minds of many anticorruption practitioners and compliance professionals: Will the SEC continue to be committed to robust FCPA enforcement?” “My answer to that question is simple,” Peikin … Continue Reading
U.S. Deputy Attorney General Rod Rosenstein pledged an enforcement environment in which businesses can thrive. In keynote remarks at the U.S. Chamber Institute for Legal Reform, he emphasized the Department of Justice’s (DOJ) commitment to “avoiding unnecessary interference in law-abiding enterprises.” Rosenstein also promoted the benefits of corporate compliance and self-reporting. Although allegedly offering “no breaking news” about DOJ policies, … Continue Reading
We have reported previously that the UK’s Serious Fraud Office (SFO) has confirmed its commitment to prosecuting bribery and corruption and that although there is yet to be a “big case” under the UK Bribery Act 2010, the SFO are busy investigating companies it suspects may have broken the law. As we approach the end … Continue Reading
A frequent topic of anti-corruption discussions is despite the aims for increased cooperation between US and foreign regulators in the wake of the Siemens case, whether increased visibility of US enforcement actions has in fact led to enforcement actions by regulators outside the United States? In the case of China, discerning an answer has been difficult. The resolution of … Continue Reading
