Compliance Communications Blog

 

"A Primer in What Not to Do"


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...

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"DOJ's Evolving Approach to Investigating Corporate Criminal Conduct"


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...

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"Does a Trade Sanction Settlement Trump Monday-Laundering Charges?"


10/1/14:
A new investigation into allegations of money laundering could derail a settlement with Germany’s Commerzbank to resolve US trades sanction violations.  A post by Richard L. Cassin on the FCPA Blog reviews an article in the Wall Street Journal (a link is provided but access to the WSJ requires a subscription) about...

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"The Other Side of Bribery"


9/15/14:
Most global companies grew up under the shadow of anti-corruption laws that criminalized the “giving side” of bribery.  Bribes 
by employees or third parties to foreign government officials have been the focus of investigations, prosecutions and settlements in the millions or even billions of dollars.  But, for every individual paying a bribe, there is...

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"Healthcare Fraud Remains Focus of DOJ"


9/1/14:
Healthcare fraud remains a focus of the US Department of Justice (DOJ) and the US Department of Health and Human Services, thanks to the Health Care Fraud Prevention and Enforcement Action Team (HEAT) initiative. To date, the US DOJ has recovered more than $14.2 billion through involving fraud against federal healthcare...

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