In the midst of a False Claims Act (FCA) case, the relators have blatantly violated the FCA’s seal provision. Surely this will lead to dismissal, right? Wrong.
On Tuesday, December 6, the Supreme Court unanimously ruled that violating the FCA’s seal requirement does not necessarily demand that a case be dismissed.
The case before…
As any company that has received a civil investigative demand (CID) from the Consumer Financial Protection Bureau (CFPB) knows, the Bureau’s authority to issue CIDs is a powerful tool that leaves recipients with limited options to challenge or limit their compliance obligations. Recently, the CFPB has fought back against CID challenges, asking two federal…
Last April, the Criminal Division of the U.S. Department of Justice launched a one-year pilot program in the Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit. The pilot program, self-described as “building” on the Yates memorandum, provides structured incentives for companies to self-disclose, cooperate, and remediate with respect to FCPA violations. The remaining…
Until relatively recently, retirement plans have not made the news as targets of data breaches. This is somewhat surprising, given the wealth of participants’ personal data stored online by these plans. This past summer, however, two plans experienced cybersecurity incidents, one involving theft and one involving ransomware.
While earlier this month, the ERISA Advisory Council…
United States Citizenship and Immigration Services (USCIS) has officially published the long awaited revised Form I-9. The new Form I-9 and instructions can be found at https://www.uscis.gov/i-9.
The clock is now ticking— While employers may begin using the new Form I-9 immediately, all employers are required to implement use of the newly revised Form…
The CFPB’s imposition of its auto lending guidelines, and use of its admittedly flawed proxy-methodology to determine discriminatory lending in auto finance, may come to an end under the GOP controlled White House and Senate.
The CFPB’s current guidance, published in a March 2013 Bulletin, has been largely criticized as limiting competition and increasing…
Public schools have generated and maintained massive amounts of student information for decades. Standardized test scores, grades, conduct records, psychological and medical information, student assessments, child and parent personal information, and teacher evaluations of children’s performance are all essential to providing and improving educational services. But with such massive amounts of data comes great risk…
“The goal is to turn data into information, and information into insight.” – Carly Fiorina, former CEO, Hewlett-Packard Co.
The most valuable asset of every organization is information. Organizing, analyzing and optimizing this complex source of business intelligence can be daunting. In addition, assuring the security of sensitive data for legal compliance and…
The UK Government introduced the Criminal Finances Bill to Parliament today (13 October 2016), which will now start its passage through the parliamentary approval process before becoming law.
The Government hopes that the Bill “will significantly improve the government’s ability to tackle money laundering and corruption, recover the proceeds of crime, and counter terrorist financing”,…
After a long and tortured route through the courts, the SEC’s final rule implementing Dodd-Frank’s Resource Extraction Payment Disclosure requirement took effect today.
Many have watched and commented on the new Rule 13q-1, and for good reason. It is likely to have a significant impact — at least in the short term — on…
