The Federal Energy Regulatory Commission (FERC) Office of Enforcement (OE) has historically focused on four “priorities,” as described in its annual Report on Enforcement. Those four priorities included (1) fraud and market manipulation; (2) serious violations of Reliability Standards; (3) anticompetitive conduct; and (4) conduct that threatens the transparency of regulated markets. In the 2021
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New Revelations in Ukraine Lead to Tightening Global Sanctions
RELATED UPDATE:
FinCEN Alert Highlights Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites and Their Proxies (January 30, 2023)
As the world watched in horror over the atrocities occurring in the war zones of Ukraine this week, global leaders re-doubled their efforts to bring increasing sanctions pressure to bear on Russian industry, the…
DOJ Publishes FCPA Declination on Cross-Border Bribery Investigation
Without fanfare, DOJ recently published a “declination and disgorgement letter,” the first FCPA declination published by the Department since August 2020.…
Largest-Ever Small-Business Contracting Fraud Settlement Related to Pass-Through Subcontracting
Federal contractors should take note of a $48.5 million False Claims Act settlement between the Department of Justice and TriMark USA LLC — the largest-ever FCA settlement based on allegations of small-business set-aside contracting fraud. DOJ alleged that TriMark had a plan to circumvent specific small-business contracting requirements by providing significant assistance to three small…
Western Companies Starting to Feel Impact of Russian Sanctions
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)
As we approach the thirty day mark since the United States, and other Western countries began imposing a series of rigorous sanctions…
DOJ Ramps up Resources and Renews Focus on Combatting COVID-19 Related Fraud in 2022
On March 10, 2022, the U.S. Department of Justice (DOJ) announced the appointment of Associate Deputy Attorney General Kevin Chambers to serve as the Director for DOJ’s COVID-19 Fraud Enforcement Task Force. In remarks delivered at the American Bar Association’s 37th National Institute on White Collar Crime earlier this month, U.S. Attorney General Merrick Garland…
FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions including Use of Virtual Currency
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…
Update: Pain Management or Pill Mill? Supreme Court Hears Arguments Regarding Standards for Prosecutions of Practitioners Prescribing Narcotics
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…
DOJ Settles First False Claims Act Enforcement Action Since Launch of Civil Cyber-Fraud Initiative
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…
Biden Administration Amends “Buy American” Rules to Increase Domestic Content Requirements
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…