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The Perils of an Ineffective Compliance Program

Are ethics programs no longer optional but mandatory? If the program is not good enough, is that fact itself the basis for liability? A recent civil case filed by the creative health care prosecutors in the U.S. Attorney's Office in Philadelphia asserts that a company's "ineffective" compliance program satisfies the scienter requirements of the civil False Claims Act (FCA).

17 minute read January 01, 2004 at 09:44 AM
By
James J. Graham
The Perils of an Ineffective Compliance Program

Are ethics programs no longer optional but mandatory? If the program is not good enough, is that fact itself the basis for liability?

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