The Department of Justice Criminal Division announced a “Pilot Program Regarding Compensation Incentives and Clawbacks” (the “Program”) this week with broad implications for corporations and their individual executives operating within the Department’s jurisdiction. During two keynote speeches delivered at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco (remarks here) and Assistant Attorney General Kenneth A. Polite, Jr. (remarks here), outlined the Program’s two key pillars.  First, moving forward, any corporate resolution with the Department’s Criminal Division must include a requirement that the company develop compliance-promoting criteria within its compensation and bonus system.  Second, Criminal Division prosecutors are instructed to provide fine reductions to companies who either successfully claw back compensation from corporate wrongdoers or undertake good-faith efforts to do so.

Arsenal Capital Partners has announced it has sold Airnov Healthcare Packaging to Colorcon.

Airnov, with manufacturing facilities in the United States and a few other countries, is a producer of consumables used to protect healthcare products from moisture and oxygen. The company’s products including drop-ins such as canisters and packets, integrated desiccant systems and plastic bottles

It has been a little more than a year since Russia’s invasion of Ukraine, and the war continues to rage.  In an effort to deter the Russian government and weaken its military capabilities, the United States has imposed significant sanctions and export controls targeting Russia.  Recognizing that these sanctions and export control laws merit aggressive enforcement, the U.S. Department of Justice (DOJ) over the past year has made investigation and prosecution of violations a priority.

Thompson Street Capital Partners (TSCP) has announced it has completed a growth investment in OpenClinica.

OpenClinica, based in Waltham, Mass., is a clinical research solutions provider. Founded in 2004, the company supports biopharmaceutical companies, contract research organizations, academic institutions and government agencies.

TSCP, based in St. Louis, Mo., targets investments in middle market

Today, the U.S. Department of Education announced it will hold individuals representing corporations or other legal entities, including a member of the board of directors or a chief executive officer, personally liable for the institution of higher education in certain circumstances. Federal Student Aid will require them to sign an institution’s program participation agreement to

Government investigators focus on pandemic-related fraud has culminated in a recent criminal conviction  As announced by the Department of Justice (DOJ), on Friday, January 13, 2023, a federal jury convicted a Colorado physician of theft for misappropriating almost $250,000 in federal COVID-19 relief funds, including both the Medicare Accelerated and Advance Payment Program (“MAAPP”) and the Paycheck Protection Program (“PPP Loans”). This is the first conviction we are aware of with respect to MAAPP to date, but marks another example of the government’s enforcement efforts to address COVID-19-related fraud. It is also a reminder for healthcare providers to remain vigilant in complying with COVID-19 relief fund program requirements as such government focus on COVID-19-related fraud continues unabated.

RLH Equity Partners has completed a growth equity investment in Connors Group, according to a news release.

Connors Group, based in Canonsburg, Pa., is a management consultancy specializing in workforce performance and productivity improvement. Founded in 2008, the company provides services to the healthcare industry and a few other industries.

RLH, with