Compliance Communications Blog

 

“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 

VIEW THE FULL POST


 

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 

VIEW THE FULL POST


 

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 

VIEW THE FULL POST


 

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,

VIEW THE FULL POST


 

Mitigating Third Party Risk

10/6/17:  An article posted by Cindy Hofmann on KPMG’s Expert Blog tackles one of the most difficult challenges facing compliance managers of global companies: third-party risk.   She offers five steps to identifying and mitigating third-party risk, beginning with getting the right information about third parties.  Hofmann’s suggestions include we should all remember (like, “Don’t rely exclusively on English searches” for information).  The article is worth reading as a reminder for compliance professionals of what they already know but may not be top-of-mind. 

VIEW THE FULL POST