Compliance

Considering DOJ’s revised Evaluation of Corporate Compliance Program Guidance, Michael Volkov speculates how companies are going to craft and implement their compliance programs to meet this latest set of expectations. “Compliance automation is a quickly becoming a basic requirement,” Volkov notes. “Technology, however, is not the single answer – controls and staff have to operate […]

Compliance attorney Jonathan Marks cautions that when considering any well run internal investigation, a CCO must be cognizant of the strictures laid out in DOJ’s updated guidance for compliance programs. “All of this ties into how the government will view an investigation, particularly if the company does not have the skills and capabilities necessary to […]

The Tenth Circuit vacated and remanded an order dismissing a qui tam suit as barred by the statute of limitations. The district court found...

The district court granted the defendants’ motion to dismiss a qui tam case alleging healthcare fraud, finding the relator’s allegations generally unsupported by concrete facts or indicia of fraud. The relator alleged the defendants failed to provide skilled nursing services, despite contractual obligations to do so, and that they continued to receive payments based on […]

DOJ’s update to its “Evaluation of Corporate Compliance Program” guidance reflects the agency’s evolving views on compliance program elements and activities, as well as the questions it asks when assessing the effectiveness of an organization’s compliance program. It can also be useful for organizations in evaluating their own compliance program effectiveness. This one-hour recorded webinar, […]

The French Ministry of Justice this month sent a memo to prosecutors outlining how it plans to investigate and prosecute illegal bribes paid by French companies to secure business in foreign countries. These plans follow the model of the United States, by encouraging companies to detect and voluntarily disclose allegations of bribery, and rewarding the […]

Bradken Inc., a subsidiary of Hitachi Construction Machinery, has paid $10,896,924 to resolve allegations that a foundry it acquired in 2008 produced and sold substandard steel components for installation on U.S. Navy submarines. The company and its former lab director Elaine Thomas – accused of falsifying metallurgical tests – have also been charged criminally. Bradken […]

ODP Systems and Timber Tech Framing, subcontractors working on an apartment complex in Eugene, Oregon, will collectively pay nearly $125,000 to 38 employees after DOL Wage and Hour Division investigators found numerous prevailing wage, overtime, and illegal deductions violations. ODP Systems violated the Davis Bacon Act by failing to pay prevailing wage rates to plasterers […]

Morrison Foerster summarizes some of the most important international anti-corruption developments from the past month. This month they ask: How will the reversal of...

The Fifth Circuit affirmed the dismissal with prejudice of a False Claims Act suit brought against Baylor Scott & White Health, a network of acute care hospitals. The suit, brought by Integra Med Analytics, alleged that Baylor submitted $61.8 million in fraudulent claims to Medicare by using unsupported “higher-value” diagnosis codes to inflate Medicare reimbursements. […]