Sunday, September 27, 2020

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Texas Woman Charged with Fraudulently Obtaining Nearly $2 Million in COVID Relief Funds

Lola Shalewa Barbara Kasali of Houston has been taken into custody on allegations she fraudulently obtained more than $1.9 million in forgivable Paycheck Protection Program loans. Kasali submitted applications on behalf of an entity called Lola’s Level and in the name of Charm Hair Extensions, each claiming numerous employees and significant payroll expenses. According to […]
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Independent Board, Budget Means Agency Does Not Qualify for “Arm of the State” Immunity...

The district court denied a state agency’s motion to dismiss a qui tam complaint alleging that it failed to pay any portion of health...

Dismissal, Says Who? Recent Seventh and Ninth Circuit Decisions Offer Competing Views on DOJ’s...

Last month, the Seventh and Ninth Circuits became the first two circuit courts to issue decisions on lower courts’ denials of government dismissal requests pursuant to its authority under the False Claims Act. With the Seventh Circuit articulating a third standard for dismissal, there is now further disagreement among the courts and within the government […]
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Compliance Regulators Don’t Stop Working when Companies Go Remote

Compliance regulators don’t take days off – not even in a pandemic. Faced with steep penalties for non-compliance and potential reputational damage, organizations are being forced to rethink their compliance strategies to account for new and emerging risks. For digital businesses today, the best place to start is by assessing how systems should be good […]
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The Herbalife FCPA Enforcement Action: Part 3 – Penalty Calculation and No Monitor

In the third of his series of blog posts about the Herbalife FCPA enforcement action, Tom Fox explores how Herbalife was able obtain such a lenient resolution: a fine and penalty of just over $133 million, and three-year deferred prosecution agreement, and no monitorship. “Before this case, if I had been asked who I thought […]
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Two Individuals Charged with Bribery Related to Iraq Contracts

Mark Alan Fryday and Lara Jumaah Mohammed, both residents of Iraq, have been charged with conspiracy and bribery of a public official, as part of the DoD Fraud Section’s ongoing efforts to combat corruption and fraud in contracting on U.S. military installations overseas. The owners of companies based in Erbil, Iraq, Fryday and Mohammed allegedly […]
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Deutsche Bank Settles Two OFAC Cases Totaling $583K for Violations of Ukraine-Russia Sanctions

Deutsche Bank has settled two separate matters with the Office of Foreign Assets Control – one involving the processing of a large transaction connected to IPP Oil Products (Cyprus) Ltd, a Specially Designated National; and another for 61 transactions involving Open Joint Stock Company Krasnodar Regional investment Bank, aka Krayinvestbank, a Specially Designated National under […]
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First-to-File Bar Not Jurisdictional, Does Not Preclude Relators From Adding New Party to Complaint;...

The Third Circuit vacated and remanded a district court decision dismissing a qui tam complaint under the first-to-file bar. Before the district court, the...

Entrapment-by-Estoppel: A Potential Future Defense for Lenders in PPP Fraud Cases

Despite express promises from the Small Business Administration that lenders participating in the Payment Protection Program may rely on borrower representations, and will not be punished for doing so, there is concern that if the government believes a lender knows or has reason to know that a borrower’s application has misrepresentations, it may still take […]
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The World Can’t Agree on Who’s a PEP. That’s a Good Thing.

Richard L. Cassin notes the irony that despite the importance of Politically Exposed Persons to the compliance profession, triggering money laundering and corruption concerns, and attracting enhanced due diligence, they are difficult to definitely identify. He observes that FinCEN, the European Union, the Financial Action Task Force, the World Bank, and the Wolfsberg Group all […]
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