The Department of Defense (DoD) issued a final rule on Covered Telecommunications Equipment or Services that implements Section 1656 of the National Defense Authorization Act for Fiscal Year 2018 (Pub. L. 115-91). To read more of our analysis, please click here.
Corporate & Commercial
The Brexit Deal; UK Crime Fighting with European Friends
Since Brexit, the relationship between the European Union (EU) and the UK concerning law enforcement cooperation is now governed by the UK-EU Trade and Cooperation Agreement (the Agreement).
The UK Government state that the safety and security of British citizens is a top priority. It argues that the Agreement provides a comprehensive package of operational…
Fraud and Abuse Rules Part III: New Value-Based Arrangement Protections
As discussed in a previous McGuireWoods alert, the Department of Health and Human Services (HHS) published final rules, effective Jan. 19, 2021, that significantly amend the Physician Self-Referral Law (Stark Law), the federal Anti-Kickback Statute (AKS) and the Civil Monetary Penalties (CMP) Law. This client alert, the latest in McGuireWoods’ summary series on these
…
Fraud and Abuse Rules Part II: Amended EHR and New Cybersecurity Donation Safe Harbors and Exceptions
As discussed in a previous McGuireWoods alert, the U.S. Department of Health and Human Services (HHS) published final rules expected to be effective Jan. 19, 2021, that significantly amend the Physician Self-Referral Law (Stark Law) and the federal Anti-Kickback Statute (AKS). This client alert, the latest in McGuireWoods’ summary series on these final rules,
…
Congress Affirms and Extends SEC’s Disgorgement Powers
On January 1, 2021, the United States Senate joined the House of Representatives in overriding President Trump’s veto, and the National Defense Authorization Act (NDAA) became law. The NDAA was passed chiefly to authorize appropriations for military activities of the Department of Defense. The NDAA also includes a provision codifying the U.S. Securities and Exchange…
Fraud and Abuse Rules Part I: Changes to Patient Inducement and Kickback Policies
As discussed in a previous McGuireWoods alert, the U.S. Department of Health and Human Services (HHS) published final rules expected to be effective Jan. 19, 2021, that significantly amend the Physician Self-Referral Law (Stark Law), the federal Anti-Kickback Statute (AKS) and the Civil Monetary Penalties (CMP) Law. This client alert, the first in McGuireWoods’
…
Stark & AKS Reform Webinar – Tues., Jan. 12, 2021
On Tues., Jan. 12, 2021, at 12 – 1 p.m. (ET) | 11 a.m. – 12 p.m. (CT) | 9 – 10 a.m. (PT), McGuireWoods will be hosting a complimentary webinar, Fraud and Abuse Regulatory Reforms: Key Themes for Private Equity-Backed Platforms.
As previously reported on The FCA Insider, the federal government recently released…
A Detailed Look At The CFPB’s Historic Approval of Payactiv’s Earned Wage Access (EWA) Program under Regulatory Sandbox Policy
Last week, we reported that on December 30, 2020, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued compliance assistance sandbox (“CAS”) approval to Payactiv, Inc. (“Payactiv”) regarding specific aspects of its earned wage access (“EWA”) product.
Payactiv’s Chief Legal Officer, David Reidy, expressed Payactiv’s reaction to the Approval Order this way – “We are…
States Sue to Set Aside OCC’s True Lender Rule
New York, California and six other States filed a widely expected lawsuit on January 5 seeking to invalidate the “True Lender” Rule recently issued by the Office of the Comptroller of the Currency (“OCC”). As we previously reported, the OCC’s True Lender Rule — finalized in October and effective since December 29 —provides bright-line…
CFPB Grants Historic Approval to Payactiv, Approving Payactiv’s Earned Wage Access (EWA) Program under Regulatory Sandbox Policy
On December 30, 2020, the Consumer Financial Protection Bureau (“CFPB”) granted approval to Payactiv, Inc. (“Payactiv”) to offer its earned wage access (“EWA”) program under the CFPB’s Policy on the Compliance Assistance Sandbox, among the first approvals under the CFPB’s regulatory sandbox.
In its approval order, the CFPB granted approval to various aspects of…