Monday, January 18, 2021

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Isolated Transactions Exception to Stark Act Scaled Back by CMS

The Centers for Medicare & Medicaid Services issued a final rule making a variety of modifications to “modernize and clarify” the regulations that interpret the Physician Self-Referral Law. For the most part, the regulations are effective January 19, 2021 (except for Amendment number 3 regarding the definition of Group Practice), and include a set of […]
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Volkov: 2020 Was a Year of Great Ethical Challenges

If ever there was a year that challenged corporate leaders on their commitment to business ethics, 2020 was the year. The number of difficult issues facing corporate leaders were challenging and ran the gamut – from health and safety concerns, to business continuity, and to economic disruptions and lay-offs or reductions in force. Even outside […]
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Compliance News: Deutsche Bank, Stablecoins, China Trade War, Trump Jobs Record

In this edition of the Daily Compliance News podcast, Tom Fox discusses: Deutsche Bank settles corruption allegations yet again. OCC approves banks use of stablecoins. China ups ante in trade war. The Trump Administration had the worst jobs record in US history. Source: FCPA Compliance Report: Daily Compliance News: January 9, 2021, The Deutsche Ban […]
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Compliance Lessons From 2020 Fraud Cases

What compliance lessons can be learned from major fraud cases in 2020, including the Goldman Sachs bribery case, the Wirecard mass corruption case, and the Novartis bribery case? Compliance experts Mikhail Gordon of Affiliated Monitors, Amii Barnard-Bahn of Barnard-Bahn Coaching & Consulting, and FCPA Compliance Report editor Thomas Fox offer an in-depth analysis in this […]
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Broward Health of Florida Officer Charged in Bribery Scheme

Brian Bravo, a former purchasing officer for Broward Health of Florida, is being charged with awarding lucrative government contracts to vendors in exchange for bribes. The kickback scheme allegedly ran from 2008 to 2015, with two vendors and a consultant for two other vendors paying Bravo hundreds of thousands of dollars in kickbacks for tens […]
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Jones Day’s FCPA 2020 Year in Review

In 2020, the biggest Foreign Corrupt Practices Act headline was the record-shattering global anticorruption enforcement fines and penalties collected by foreign regulators in actions...

Stark Law and Anti-Kickback Statute Reform: Six Key Insights for Private Equity Healthcare Affiliations

Two new healthcare fraud and abuse final rules, effective Jan. 19, 2021, may increase flexibility for private equity firms exploring opportunities in the healthcare space as well as private equity-backed healthcare platforms as they consider transactions, investment/alignment opportunities, patient engagement approaches and other business opportunities. The new final rules released by the Centers for Medicare & […]
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Doreen Edelman, on Biden’s Committee on Foreign Investment in the United States

In a new podcast episode, Tom Fox interviews Doreen Edelman, chair of the Lowenstein Sandler Global Trade & Policy practice, about the Committee on Foreign Investment in the United States (CFIUS) and where it is headed under the Biden Administration. In her role with Lowenstein Sandler, Edelman leads a unique team that combines global trade […]
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2021 FCPA Predictions (Part IV of IV)

Michael Volkov acknowledges that the pandemic upset the assumptions for his 2020 predictions, while his main correct prediction – the Goldman Sachs enforcement – was fairly obvious following the company’s 2019 disclosure. For 2021, he anticipates that President Biden’s Department of Justice will factor significantly, though its impact in FCPA enforcement may not be felt […]
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Miratech’s Compliance Management Lessons of 2020

Michael Rasmussen describes 2020 as “a year of health and safety, environmental, information security, conduct, and leadership disasters, but also a year of metamorphosis.” He identifies a dozen compliance and ethics lessons, related to operational integrity, compliance risk management, employee engagement, policies, third-parties, and defensible compliance. One overarching lesson is organizations’ need for a federated […]
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