On March 2, 2022, the U.S. Department of Education’s Office of Federal Student Aid (FSA) for the first time asserted regulatory authority over income share agreements (ISAs) as private education loans. FSA issued an electronic announcement to clarify its authority over income share agreements at institutions that receive federal aid under the Higher Education Act
First FCPA Settlement of 2022 – Enforcement on the Horizon
On February 17, 2022, the Securities and Exchange Commission (SEC) announced the first Foreign Corrupt Practices Act (FCPA) settlement of the year. Seoul-based KT Corporation (KT Corp.), South Korea’s largest telecommunications operator, will pay $6.3 million to resolve charges that it violated the FCPA by providing improper payments for the benefit of government officials in
U.S. and Allies Significantly Expand Sanctions and Related Restrictions on Russia and Belarus
RELATED UPDATES:
New Revelations in Ukraine Lead to Tightening Global Sanctions (April 8, 2022)
Western Companies Starting to Feel Impact of Russian Sanctions (March 24, 2022)
FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions including Use of Virtual Currency (March 16, 2022)
DOJ Launches “Task Force KleptoCapture” in Response to
Pain Management or Pill Mill? Supreme Court to Weigh in on Standards for Prosecutions of Practitioners Prescribing Narcotics
Update: Pain Management or Pill Mill? Supreme Court Hears Arguments Regarding Standards for Prosecutions of Practitioners Prescribing Narcotics (March 11, 2022)
Introduction
Next week, the Supreme Court will hear oral argument in a pair of cases that may reshape the landscape of legitimate prescribing under the Controlled Substances Act (“CSA” or “the Act”). In companion
Additional Sanctions on Russia and the Importance of Business Contingency Planning
RELATED UPDATES:
New Revelations in Ukraine Lead to Tightening Global Sanctions (April 8, 2022)
Western Companies Starting to Feel Impact of Russian Sanctions (March 24, 2022)
FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions including Use of Virtual Currency (March 16, 2022)
DOJ Launches “Task Force KleptoCapture” in Response to
Biden Administration Issues Initial Ukraine Sanctions
RELATED UPDATES:
New Revelations in Ukraine Lead to Tightening Global Sanctions (April 8, 2022)
Western Companies Starting to Feel Impact of Russian Sanctions (March 24, 2022)
FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions including Use of Virtual Currency (March 16, 2022)
DOJ Launches “Task Force KleptoCapture” in Response to
EARN IT Act Opens Online Service Providers to Liability for Online Child Sexual Abuse Hosted on Their Platforms
On Thursday, February 10, 2022, the Senate Judiciary Committee approved the Eliminating Abusive and Rampant Neglect of Interactive Technologies Act (EARN IT Act), first introduced in 2020 by Sens. Lindsey Graham, R-SC, and Richard Blumenthal, D-Conn. The EARN IT Act aims to tackle the online proliferation of child sexual abuse material (CSAM) by paring back
Analysis of DOJ’s 2021 FCA Statistics and the Trends Therein
Last week, the U.S. Department of Justice (DOJ or Department) announced that it recovered over $5.6 billion under the False Claims Act (FCA) in Fiscal Year 2021.[1] That is a massive headline haul that is second only to the roughly $6 billion recovered under the FCA in FY 2014, when there were $3.1 billion
Analysis of DOJ’s 2021 False Claims Act Statistics and Related Trends
Last week, the U.S. Department of Justice announced that it recovered more than $5.6 billion under the False Claims Act in fiscal year 2021 — an enormous total, second only to 2014 recoveries.
Read the latest post on “Subject to Inquiry” for analysis of the reported 2021 statistics, how they compare to previous years’
Seventh Circuit Clarifies Pleading Standard for Anesthesiologist’s False Claims Action
The Seventh Circuit recently reversed a lower court’s ruling that an amended complaint in a qui tam lawsuit filed under the False Claims Act (FCA) alleging fraudulent anesthesiology billing practices failed to meet the pleading standard under Rule 9(b) of the Federal Rules of Civil Procedure. In U.S. ex. rel. Mamalakis vs. Anesthetix Management LLC,