Heritage Group has invested in TwelveStone Health Partners, according to a news release.

TwelveStone, based in Murfreesboro, Tenn., is a provider of comprehensive chronic care medication services. Launched in 2016, the company’s offerings include ambulatory infusion, home infusion and packaged medication delivery.

Heritage Group, based in Nashville, Tenn., makes control and minority

The Centers for Medicare & Medicaid Services recently announced an opportunity for public comment on its voluntary self-referral disclosure protocol (SRDP). The voluntary SRDP is a way to resolve technical violations under the physician self-referral law (commonly known as the Stark Law) by submitting information to CMS about prohibited conduct. During this period, CMS is

The federal wire fraud statute has a far-reaching scope, allowing prosecutors to go after conduct as varied as investor fraud to college admissions scandals. In late June, the Fourth Circuit U.S. Court of Appeals arguably broadened that scope even further by affirming a wire fraud conviction for a defendant who devised the scheme from Israel. Although the statute only applies domestically, the Fourth Circuit held that a foreign defendant can be convicted of wire fraud as long as U.S. wires were used to transmit the fraudulent messages.

Norwest Equity Partners (NEP) has announced it has completed an investment in QTI Fibers.

QTI, based in Colfax, N.C., is a designer and manufacturer of technical fibers, fabrics and coatings for healthcare and other applications. Founded in 1922, QTI is comprised of three brands: Twitchell Technical Products, Quantum Materials and Infinity Woven Products.

Norwest

DOJ’s dismissal last week of a Foreign Corrupt Practices Act case in Boston is the latest in a string of bad outcomes for the government due to discovery mishaps. While the government works to revise its discovery policies and seek resources to collect, review, and analyze the vast amount of electronic evidence attendant to nearly every federal criminal investigation, defense counsel should hold the government to account and formally demand discovery early and often.

The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively the “Agencies”) issued a Joint Statement on July 6, 2022, reminding banks[1] of the “risk-based approach to assessing customer relationships and conducting customer due diligence (CDD).”  The Joint Statement reminds banks that the Agencies consider a blanket approach of assessing customer risk, based solely on the type of customer (e.g., casino, auto dealer, etc.), to be inappropriate.  Specifically, the Joint Statement urges financial institutions not to simply ascribe the same level of risk to all customers of a particular type. Rather, banks must use a risk-based approach that evaluates the specific customer at issue when creating customer profiles and when establishing and maintaining customer relationships.  Further, the Joint Statement expresses a preference for enhanced monitoring rather than exiting customer relationships as part of de-risking.[2]

On May 27, 2022, Plaintiff Melanie E. Damian, in her capacity as the Court-Appointed Receiver for Today’s Growth Consultant, Inc. d/b/a The Income Store (“TGC”) (the “Receiver”) filed a complaint against Defendant SmithAmundsen, LLC (“Defendant”) in the Northern District of Illinois seeking damages, restitution, interest, and costs.  Specifically, the complaint alleges two claims for legal malpractice and aiding and abetting breach of fiduciary duty.

This action stems from a prior action filed by the Securities and Exchange Commission (“SEC”) against TGC and its founder, Kenneth D. Courtright, III (“Courtright”), wherein the SEC alleged TGC and Courtright violated federal securities laws and sought civil penalties and injunctive relief to halt their wrongful activity.

We previously wrote about PLB Investments LLC et al v. Heartland Bank and Trust Co. et al., a related case initiated by various defrauded investors of TGC against two bank defendants concerning TGC’s website services Ponzi scheme.

On June 22, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a Statement on Bank Secrecy Act Due Diligence for independent ATM owners and operators.  The purpose of the statement is to “provide clarity to banks on how to apply a risk-based approach to conducting customer due diligence (CDD) on independent Automated Teller Machine (ATM) owners or operators, consistent with the requirements set out in FinCEN’s 2016 CDD Rule.”

Under FinCEN’s 2016 CDD Rule, banks are required to establish and maintain written policies and procedures reasonably designed to identify and verify “beneficial owners of legal entity customers.”   This Rule extends to conducting CDD on independent ATM owners and operators who maintain bank accounts to supply cash for their ATMs and to settle the electronic funds transfers used to process ATM transactions.

TPG Capital will take Convey Health Solutions Holdings (NYSE: CNVY) private, according to a news release.

Convey, based in Fort Lauderdale, Fla., is a specialized healthcare technology and services company. Founded in 2001, the company solutions, designed for government-sponsored health plans, are designed to support member interactions, compliance and Medicare processes.

TPG Capital