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
On May 19, 2020, in response to the COVID-19 pandemic, President Trump signed Executive Order 13924, to provide regulatory relief for entities economically impacted by the pandemic. Section 6 of the Executive Order directed agencies to revise their procedures and practices in administrative investigations and enforcement in light of certain enumerated principles of fairness. It … Continue Reading
Every organization is at risk of a data breach, and can learn something from Uber’s data privacy missteps. In an article for Corporate Compliance Insights, Squire Patton Boggs lawyers Colin Jennings, Ericka Johnson, and Dylan Yépez offer key takeaways from the company’s high-profile data breaches and the criminal charges that followed.… 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
Not too long ago I was clicking through the greatly improved DOJ FCPA webpage when I stumbled onto an enforcement action that had flown under the anticorruption/compliance blogosphere’s radar. Yes, Manuel Salvoch had escaped the dreaded DOJ press release, but not the Fraud Section’s posting of documents for the world to see. It was only … Continue Reading
On Friday, March 11, Jeffrey Tesler, who had challenged extradition from the UK to the US, relented in his fight and pleaded guilty to one count of conspiracy to violate the FCPA and one substantive violation of an FCPA antibribery provision. In 2009, the DOJ initially charged Tesler in an 11 count indictment consisting of … Continue Reading
Recently, we wrote about the 2010 enforcement environment. Today’s post looks forward to 2011 and some things to keep an eye out for in the coming year. Without further ado: Prosecutions of Individuals. In 2010 we saw a significant number of individuals prosecuted for FCPA and related violations. A number of defendants resolved their prosecutions … Continue Reading
