Compliance Communications Blog

 

Tracking Down Potential Bribery

3/14/18: 

Cody Worthington recently posted an article to The FCPA Blog about an often-overlooked indicator of fraud: the balance sheet.  He should know.  Worthington is a Certified Fraud Examiner, Internal Auditor and Public Accountant in addition to his other roles.  He cautions, “… don’t overlook the balance sheet.

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“No-Poach” and “Wage Fixing Agreements” On DOJ’s Radar

2/23/18: 

Keeping labor costs in check is part of doing business.  So is keeping and retaining good employees.  But, the US Department of Justice has made clear that “no poach” and “wage fixing” agreements are not a legal way to accomplish any of those objectives. In a post on Law 360, Juan A. Arteaga, a partner with law firm Crowell & Moring, drills into the DOJ Anti-Trust Division’s scrutiny of 

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Enforcement Risk Beyond National Regulators

2/23/18: 

Companies may know about the risks of noncompliance from their own national regulators or even transnational laws, but the consequences of noncompliance reach all the way to major global funding organizations.  According to a post by Richard L. Cassin on the FCPA Blog, The World Bank has debarred three Argentina-basedconstruction companies for 

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Medicare Advantage Under DOJ Scrutiny for Overpayments

2/23/18: 

CMS’ Medicare Advantage (MA) represents a lucrative opportunity for many healthcare companies.  It’s also a growing opportunity as Medicare beneficiaries increasingly choose it over traditional Medicare.  So, when CMS estimates that it overpaid MA organizations about $1.4 billion 

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Government Contractor Heads to Prison for Interactions with Government Official

2/23/18:  Most discussions about bribery of government officials involves the Foreign Corrupt Practices Act, but Michael Allen Braun provides a different lesson for US government contractors as he heads to jail for 18 months.  The sentence was for Braun’s conspiracy to commit theft of honest services, wire fraud and bribery of a US public official – not a foreign government official.  His co-conspirator,

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