RELATED UPDATES:
FinCEN Alert Highlights Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites and Their Proxies (January 30, 2023)
New Revelations in Ukraine Lead to Tightening Global Sanctions (April 8, 2022)
Western Companies Starting to Feel Impact of Russian Sanctions (March 24, 2022)

The Financial Crimes Enforcement Network (FinCEN) has issued an alert encouraging all financial institutions to be “vigilant” against efforts by their customers to evade recent sanctions and other restrictions imposed by the United States on the Russian Federation in connection with its invasion of Ukraine.

In recent weeks, the United States has increased sanctions and export controls on the Russian economy as part of a coordinated effort with the European Union and United Kingdom. These include:

  • Sanctions against persons operating in the financial sector of the Russian Federation;
  • Prohibitions on correspondent or payable-through accounts and payment processing for certain Russian institutions;
  • Blocking of certain Russian financial institutions and other entities, including Russian elites and their families;
  • Prohibitions on dealing in new sovereign debt or new debt and equity issuances by certain Russian entities; and
  • Extensive limitations on Russia-related import and export activities.

On March 9, 2022, President Biden signed an Executive Order on Ensuring Responsible Development of Digital Assets (“Executive Order”) to mobilize the federal government to develop a strategy for digital assets, intending to encourage innovation in a manner that mitigates the risks to consumers, investors, and businesses. The Executive Order mandates an interagency approach across several executive departments and federal agencies to conduct reports and analyses on key issues impacting digital assets, including consideration of U.S. Central Bank Digital Currencies (“CBDC”). The Executive Order identifies six primary policy objectives:

  • protect U.S. consumers, investors, and businesses;
  • protect U.S. and global financial stability and mitigate systemic risk;
  • mitigate the illicit finance and national security risks posed by misuse of digital assets;
  • reinforce U.S. leadership in the global financial system and in technological and economic competitiveness;
  • promote access to safe and affordable financial services; and
  • support technological advances that promote responsible development and use of digital assets.

    • Argosy Healthcare Partners (AHP) has announced it has completed a recapitalization of Specialty Care Management (SCM).

    SCM, based in Bucks County, Pa., is a payor services company focused on healthcare cost containment and claims management services for the self-insured market. Founded in 2002, the company specializes in program design for catastrophic claims.

    AHP,…

    Last week, the Supreme Court (Court) heard oral arguments in companion cases Ruan v. United States and Kahn v. United States, concerning the application of the Controlled Substances Act (“CSA” or “the Act”) to medical practitioners. Through these cases, the Court is expected to resolve a circuit split over the role of “good faith” as a defense for medical practitioners charged with unlawfully distributing narcotics under Section 841(a) of the Act (see our previous article about the issues before the Court and the different approaches to good faith taken by the circuit courts). While arguments did not offer a clear view into the direction the Court is headed, three points of friction emerged that may inform the Court’s decision.

    On March 8, the U.S. Department of Justice announced a $930,000 settlement with Comprehensive Health Services, LLC for alleged violations of the False Claims Act. As DOJ’s first resolution of a False Claims Act enforcement action involving cyber fraud since launching its Civil Cyber-Fraud Initiative in October 2021, this settlement signals the DOJ’s eagerness to…

    On March 8, 2022, the U.S. Department of Justice (DOJ) announced a $930,000 settlement with Comprehensive Health Services, LLC (CHS) for alleged violations of the False Claims Act (FCA). This settlement marks DOJ’s first resolution of an FCA enforcement action involving cyber fraud after launching its Civil Cyber-Fraud Initiative in October 2021, signaling DOJ’s eagerness to combat cybersecurity violations and misrepresentations.

    On March 7, the Federal Acquisition Regulatory Council promulgated a final rule aimed at increasing federal government preferences for goods and construction materials that are domestically manufactured and increasing the required domestic content threshold for purchases governed by the Buy American Act.

    Read on for highlights from the rule and next steps for government contractors…