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In May 2018, the Department of Justice (DOJ) announced a new policy to address a growing problem in white-collar criminal and civil enforcement. With increased frequency, law enforcement investigations of financial institutions and multinational corporations involve cooperation and information-sharing among governments, as well as among U.S. federal, state and local agencies. As Steven R. Peikin, co-director of the U.S. Securities and Exchange Commission’s (SEC) Division of Enforcement, observed in a speech in November 2017: “The level of cooperation and coordination among regulators and law enforcement worldwide is on a sharply upward trajectory.” As a result, companies have faced multiple — and often duplicative — penalties in numerous jurisdictions, particularly in the area of anticorruption enforcement.
By Jacqueline C. Wolff
Lessons Learned from Recent Settlements and Decisions
Health care fraud and False Claims Act cases continue to generate a significant source of funds for the Federal Government. Although, when announcing its focus, the government listed treatment options are not always clear. What these settlements often have in common is that the underlying complaints allege that the services that were rendered and reimbursed lacked medical necessity.
By Robert J. Anello and Justin Roller
Part Two of a Two-Part Article
Though they might seem straightforward on their faces, limitations periods are often elongated by legislation or court interpretation. The authors began looking at some of these exceptions to the stated limitations periods last month in Part One of this article. They continue here with further examples.
By Colleen Snow
Utah Biodiesel Executives in $511 Million Fuel Tax Credit Scheme
By Colleen Snow
Second Circuit Issues Ruling Against DOJ in United States v. Hoskins Appeal