Compliance

“Prevention Is Priceless: FCA Protection in the Healthcare Industry” is the fourth episode of Ex Rel. Radio, PilieroMazza’s multi-part series on the False Claims Act. In this episode, counsel Michelle Litteken joins host Jon Williams to discuss how the False Claims Act affects companies in the healthcare industry, potential risks these companies face, and strategies […]

A recent Securities and Exchange Commission action against a federal contractor highlights the importance of having a strong internal compliance and investigation program, as well as the potential a company’s financial records could come under review by more than one federal entity. In L3 Techs., Inc., Rel. No. 3844, L3 Technologies agreed to pay the […]

In part 2 of his series on the FCPA enforcement action against Russian telecom Mobile TeleSystems PJSC, Tom Fox examines the details of the schemes used by MTS to pay the bribes and the steps the recipient used to receive them.  Read the full post at FCPA Compliance Report

Home Furnishings Resource Group Inc. will pay $500,000 to resolve allegations that it violated the False Claims Act by making false statements on customs declarations to avoid paying anti-dumping duties on wooden bedroom furniture imported from the People’s Republic of China. According to the settlement, HFRC misclassifed furniture as non-bedroom furniture on its official import documents. […]

Former U.S. Navy senior chief Clayton Pressley III was sentenced to two years in prison for his involvement in a procurement fraud scheme that resulted in a $2.3 million loss to the Navy. Pressley conspired with two others to form a sham contracting firm, ostensibly to provide “inert training aids” to local Navy units. However, […]

The FCA continues to be the federal government’s primary civil enforcement tool for investigating allegations that healthcare providers or government contractors defrauded the federal government. In the coming weeks, we continue to take a closer look at recent legal developments involving the FCA. This week, we examine the FCA’s first-to-file rule and its impact on […]

Luke Hilliard, the former CEO of Virginia-based defense contractor Atlantic Diving Supply, has agreed to pay $20 million to settle False Claims Act allegations. Ameliorate Partners LLP filed the lawsuit under the whistleblower provisions of the False Claims Act, alleging that Hilliard falsely represented ADS as qualifying for small-business set-aside contracts, several of which it […]

The past 18 months have been a (relatively) wild time for the False Claims Act — on the books since 1863. In FY2018 the...

CITGO Petroleum Company – owned by state-owned Petróleos de Venezuela, S.A. – has sued its former agent José Manuel González Testino, for harm allegedly caused by his payment of bribes to foreign officials. Ironically, the bribes were paid to CITGO’s own employees, who are considered foreign officials under the FCPA. Last year, González Testino pleaded guilty […]

Mike Koehler questions the SEC’s recent Barclays Foreign Corrupt Practices Act enforcement action based on alleged improper internship and hiring practices. He notes that the company had policies and procedures that included prohibitions on providing employment in exchange for business, and specifically required “compliance monitoring” in the hiring process. These were ignored or circumvented by […]