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
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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…
DOJ Launches “Task Force KleptoCapture” in Response to Russian Invasion
RELATED UPDATES:
New Revelations in Ukraine Lead to Tightening Global Sanctions (April 8, 2022)
Western Companies Starting to Feel Impact of Russian Sanctions (March 24, 2022)
FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions including Use of Virtual Currency (March 16, 2022)
Last week, the U.S. Department of Justice (DOJ)…
U.S. Department of Education Officially Asserts Authority over Income Share Agreements
On March 2, 2022, the U.S. Department of Education’s Office of Federal Student Aid (FSA) for the first time asserted regulatory authority over income share agreements (ISAs) as private education loans. FSA issued an electronic announcement to clarify its authority over income share agreements at institutions that receive federal aid under the Higher Education Act…
First FCPA Settlement of 2022 – Enforcement on the Horizon
On February 17, 2022, the Securities and Exchange Commission (SEC) announced the first Foreign Corrupt Practices Act (FCPA) settlement of the year. Seoul-based KT Corporation (KT Corp.), South Korea’s largest telecommunications operator, will pay $6.3 million to resolve charges that it violated the FCPA by providing improper payments for the benefit of government officials in…
U.S. and Allies Significantly Expand Sanctions and Related Restrictions on Russia and Belarus
RELATED UPDATES:
New Revelations in Ukraine Lead to Tightening Global Sanctions (April 8, 2022)
Western Companies Starting to Feel Impact of Russian Sanctions (March 24, 2022)
FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions including Use of Virtual Currency (March 16, 2022)
DOJ Launches “Task Force KleptoCapture” in Response to…
Pain Management or Pill Mill? Supreme Court to Weigh in on Standards for Prosecutions of Practitioners Prescribing Narcotics
Update: Pain Management or Pill Mill? Supreme Court Hears Arguments Regarding Standards for Prosecutions of Practitioners Prescribing Narcotics (March 11, 2022)
Introduction
Next week, the Supreme Court will hear oral argument in a pair of cases that may reshape the landscape of legitimate prescribing under the Controlled Substances Act (“CSA” or “the Act”). In companion…