Saturday, January 23, 2021

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FCPA/Anti-Corruption Developments: Steptoe’s 2020 Year in Review

Despite the challenges presented by the global COVID-19 pandemic, FCPA enforcement authorities announced several high-profile individual and corporate enforcement matters throughout 2020, including several coordinated resolutions with foreign authorities as well as new domestic players. Overall, while the number of enforcement actions was slightly down from 2019 (34 total enforcement actions, 23 of which were […]
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An Ounce of Prevention: Effective Corporate Policies for Dealing with Government Investigations and Inquires

One of the first indicators that may tip off a healthcare provider or government contractor that their organization may be the subject of a False Claims Act (FCA) investigation is contact with a government investigator.  That contact may take many forms – service of a subpoena or Civil Investigative Demand (CID), an interview of an […]
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Arnold & Porter’s Global Anti-Corruption Insights

While the pace of enforcement of the US Foreign Corrupt Practices Act (FCPA) dipped in the initial months of the COVID-19 pandemic, 2020 ended up being a record-breaking year for corporate resolutions of FCPA-related cases. Bookended by two multi-billion-dollar, multi-jurisdictional settlements in the Airbus SE and Goldman Sachs cases, the Department of Justice (DOJ) and […]
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FCPA Update: Enforcement Continues

In recent months, the U.S. Department of Justice (DOJ) and Securities & Exchange Commission (SEC) have announced several notable penalties for violations of the U.S. Foreign Corrupt Practices Act (FCPA). The FCPA prohibits bribery of foreign government officials and requires issuers of securities on U.S. exchanges to keep and maintain accurate books and records and […]
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SBA OIG Raises Concerns about PPP Loan Recipients on Treasury’s Do Not Pay List

On January 11, 2021, the Small Business Administration (SBA) Office of Inspector General (OIG) released a Management Alert raising concerns about improper payments to lenders for potentially ineligible recipients of loans under the SBA’s Paycheck Protection Program (PPP). The SBA OIG and Department of Treasury Do Not Pay (DNP) Business Center conducted an analysis seeking […]
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What You Need to Know about the Corporate Transparency Act

On January 1, Congress passed the 2021 National Defense Authorization Act, which includes the Corporate Transparency Act. The CTA requires all U.S. businesses to file “beneficial ownership” information with the Financial Crimes Enforcement Network. It is designed to ban the anonymous shell companies that criminals and certain foreign officials use to hide and move corrupt […]
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OFAC Takes Action Against BitGo and National Commerce Bank

OFAC reported two new enforcement actions in the week between Christmas and New Year’s. These are interesting examples of sanctions enforcement, one of which involved the first against a digital currency company. BitGo, Inc. a technology platform that provides digital asset wallet management, agreed to pay $98,830 to settle 183 apparent violations of multiple sanctions […]
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SBA OIG Management Alert Raises Serious Concerns Over Paycheck Protection Program Loan Recipients on...

On January 11, 2021, the Small Business Administration (SBA) Office of Inspector General (OIG) released a Management Alert raising concerns about improper payments to lenders for...

Improper Billing of “P-Stim” Devices is Focus of Recent FCA Settlements

Improper billing for electro-acupuncture using a “P-Stim” device (or peri-auricular stimulation device) has been the subject of two False Claims Act (FCA) settlements already in 2021, following a trend of such enforcement actions within the past year. Each of the recent settlements, detailed further below, involve providers billing federal healthcare programs for acupuncture using P-Stim […]
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A Year of Developments and a Look Ahead for DOJ Procurement Collusion Strike Force

In 2019, Arnold & Porter wrote about DOJ's new multi-agency Procurement Collusion Strike Force. Formed in November 2019, this Antitrust Division initiative focuses on...