In SEC v. Jarkesy, No. 22-859, 603 U.S. __ (2024), the Supreme Court held that the Seventh Amendment prohibits the Securities and Exchange Commission (SEC or Commission) from seeking civil penalties in certain enforcement actions when the Commission chooses to proceed in-house before its own administrative law judges (ALJs), rather than in federal court. In a 6-3 opinion written by Chief Justice Roberts, the Court held that the Seventh Amendment requires, at a minimum, that any fraud action involving civil penalties be tried in front of a jury in federal court. The Court’s decision will have immediate implications for the SEC’s enforcement program and will likely have broader implications for administrative adjudications for a host of federal agencies and federal laws.

Argosy Healthcare Partners (AHP) has announced the recapitalization of Connect Life Sciences (CLS).

CLS, founded in 2020 and based in Orlando, Florida, provides recruitment services to pharmaceutical, biotechnology and medical device companies.

AHP, based in Wayne, Pa., is a lower middle market private equity investor focused exclusively on healthcare. A division of Argosy

Triton Pacific Healthcare Partners has announced the closing of its sale of BioMatrix Specialty Infusion Pharmacy to Frazier Healthcare Partners. 

BioMatrix, founded in 2001 and based in Plantation, Florida, is a provider of specialty infusion services in the United States. 

Triton Pacific Healthcare Partners is the healthcare division of Triton Pacific Capital Partners.

On June 26, Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of an enforcement action against an Italian animation company that violated OFAC’s sanctions on North Korea. The enforcement action highlights several key propositions regarding sanctions compliance: (1) non-U.S. businesses cannot ignore U.S. sanctions if they are transacting through the U.S. or using U.S. dollars; (2) penalties for civil violations of sanctions are imposed on a strict liability basis; and (3) the U.S. government is particularly focused on North Korean sanctions evasion.

Altaris has announced it will acquire Sharecare (NASDAQ: SHCR) for $1.43 in cash per share, or about $518 million.

Sharecare, founded in 2010 and based in Atlanta, is a digital health company that provides technology and services across the healthcare ecosystem through three business channels: enterprise, provider and life sciences.

Altaris, based in

Last month, the U.S. District Court for the District of New Jersey held that a private company, Allstate Insurance Company, could proceed with its whistleblower action against a clinical laboratory, Phoenix Toxicology and Lab Services, LLC, which allegedly submitted false claims to the federal government for medically unnecessary urine drug tests (“UDT”). See generally United States ex rel. Allstate Ins. Co. v. Phoenix Toxicology & Lab Servs., LLC, No. CV 22-6303, 2024 WL 2785396 (D.N.J. May 30, 2024). This lawsuit is part of a growing trend of non-traditional, whistleblower-like insurance companies, activists, investors, special purpose entities created just to file litigation (sometimes created by attorneys or litigation-funding groups) and others to file False Claims Act (“FCA”) actions, which have traditionally been brought by former or current employees of the target entities.

Notable litigation filed during May 2024 includes: (1) Courtney v. Sawyer, et al., No. 24-cv-37962 (Cal. Super. Ct.); (2) two related actions by a court-appointed receiver, captioned Dottore v. FTF Lending, LLC, et al., No. CV-2024-05-1878 (Ohio Ct. Comm. Pl.); Dottore v. MHS Investors LLC, No. CV-2024-05-1904 (Ohio Ct. Comm. Pl.); and