General
The Justice Department’s Antitrust Division recently announced a $100 million settlement with Florida Cancer Specialists & Research Institute (“FCS”) for an illegal conspiracy to allocate cancer patients in Southwest Florida. FCS conspired with various competitors to allocate medical and radiation oncology treatments. The $100 million criminal penalty is the
General
OFAC announced a $257k settlement with Biomin America, Inc. (“Biomin”), an animal nutrition company based in Overland, Kansas, to settle violations of the Cuban Sanctions Program. OFAC recently issued guidance suggesting that organizations may re-allocate or reduce sanctions compliance operations based on the impact of the pandemic on an
Podcasts
In a two-part series, Michael Volkov examines the continuing problem of identifying and mitigating beneficial ownership risks. Money launderers and corrupt individuals continue to rely on corporate structures to disguise their ownership interests to further illicit schemes. Companies have to develop strategies that practically address the risks without dedicating
Podcasts
In a two-part series, Michael Volkov examines the continuing problem of identifying and mitigating beneficial ownership risks. Money launderers and corrupt individuals continue to rely on corporate structures to disguise their ownership interests to further illicit schemes. Companies have to develop strategies that practically address the risks without dedicating
General
The global pandemic has created unique risks for handling employees’ exposure to, or positive testing for, COVID-19. To ensure a safe workplace, companies have to address delicate issues surrounding employee safety. The United States does not have a federal privacy law to address this specific situation (unlike Europe and
General
In the Chipotle Mexican Grill case, DOJ entered into a three-year deferred prosecution agreement (“DPA”) in exchange for the payment of a $25 million penalty stemming from a string of foodborne-illness cases between 2015 and 2018 involving its restaurants in which more than 1100 people became ill. The
General
In an important set of criminal prosecutions for food safety violations, the Justice Department recently announced resolutions with Blue Bell Creameries and Chipotle Mexican Grill. While these cases were not related to the COVID-19 pandemic, they are indications of DOJ’s aggressive prosecution for food safety issues and are
General
You can always count on cyber-criminals and fraudsters to come out of the woodwork when a national crisis occurs. The COVID-19 pandemic has resulted in a multitude of criminal schemes. Companies that rely on remote employees have to be vigilant in alerting employees to phishing, malware and other
Podcasts
The Justice Department recently resolved two food safety criminal cases involving Blue Bell Ice Cream and Chipotle Mexican Grills. In its largest food safety recovery to date, Chipotle agreed to a three-year deferred prosecution agreement and paid $25 million. In the Blue Bell Ice Cream case, Blue Bell agreed
General
If there ever was a time that companies need to promote and encourage employee reporting, the time is now. By employee reporting, I do not mean to single out hotline reporting – certainly that is one of many avenues to report concerns. In this era of fear and worry, companies need
General
Human Resources and Compliance have always had a natural and tight bond, assuming that there is no territorial or in-fighting political disputes. In this new COVID-19 pandemic era, the HR and Compliance partnership is even more important. HR and Compliance have a critical challenge for moving forward – restoring
General
The COVID-19 pandemic era has transformed the economy with a new emphasis on health and safety related products (e.g., sanitizers, toilet paper, designated medical supplies). Our economy has suffered severe disruptions to demand and supply of goods and services. In this new economy, businesses face extraordinary risks of