The most instructive and thus important enforcement actions tend to be those that take the Foreign Corrupt Practices Act in a new direction, involve unique interpretations of law (not subjected to any judicial scrutiny of course) and thus pose new compliance challenges for business organizations. The SEC’s 2004 enforcement action against Schering-Plough, based on a bona-fide charitable contribution, certainly fits this mold.
Regulations, Compliance, & Enforcement
Trending Now
One Part Legal, One Part Behavioral: A Winning Recipe for a More Thoughtful Compliance Program • DOJ Has Agreed Not to Oppose Entry of Judgment On Three Specific Biden-Era Davis-Bacon Act Rules Involving Materialmen, Truckers, and the Application of the Christian Doctrine. • A Decade Later, Escobar Is Still Shaping FCA Cases • Senate Panel Advances NDAA Measure Restricting Defense Contractor Stock Buybacks • AI Is Taking Background Checks from ‘Months to Hours,’ Clearance Agency Says
Dubious As It Was, The Schering-Plough Enforcement Action Was Notable
Track False Claims Act cases, audit trends, and compliance best practices with our Compliance & Enforcement newsletter, delivering up-to-the-minute intelligence Monday–Saturday — Subscribe here.