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10/15/14: The US Department of recently filed suit against a pharmaceutical company and its founder, owner and Chairman of the Board for violations to the Federal Food, Drug and Cosmetic Act (FD&CA) by manufacturing and distributing “adulterated and misbranded medical devices.” By itself, DOJ’s decision isn’t groundbreaking news but...
Compliance Communications Blog
Oct 15, 2014 •
Oct 15, 2014 •
9/15/14: This may not come as a huge surprise, but it appears that recent studies confirm the connection between gifts or money from healthcare companies and decisions by healthcare providers and even regulatory decision-makers. According to a recent study, there was a “powerful correlation” between the voting behaviors and...
Oct 15, 2014 •
10/15/14: The Financial Crimes Enforcement Network (FinCEN) is not amused by recent enforcement actions against financial institutions. According to a post by Michael Volkov on Corruption, Crime & Compliance, FinCEN’s frustration is based on what the agency believes are the “paper compliance programs” used by many financial institutions...
Oct 01, 2014 •
10/1/14: In a post on his Conflict of Interest blog, Jeff Kaplan asks a basic question: to whom does the person responsible for compliance report? The CEO? The Board of Directors? The General Counsel? Fortunately, Jeff offers some useful ways of looking at the question and the possible answers. He also provides links to two recent...
Oct 01, 2014 •
10/1/14: In mid-September, Principal Deputy Assistant Attorney General for the Criminal Division Marshall L. Miller spoke at the Global Investigation Review Program about DOJ’s evolving approach to investigating “… criminal conduct when it takes place at corporations and other institutions.” Miller said, “ … in today’s Criminal Division, we are...
