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Vince Farhat

White Collar Defense & Investigations OIG Issues Special Telehealth Fraud Alert

During the COVID-19 pandemic, healthcare providers greatly expanded their use of telehealth services to provide medically necessary care to their patients. Practitioners’ increased use of telehealth services also led to greater law enforcement scrutiny by the U.S. Department of Health and Human Services Office of Inspector General (OIG) and the U.S. Department of Justice (DOJ). […]

White Collar Defense & Investigations White Collar Enforcement Forecast: What to Expect in 2022

The Biden Administration is ramping up white collar enforcement in 2022. Whereas fines and prosecutions of white collar offenses declined under the previous administration, we are seeing increased white collar enforcement under the Biden Administration as it implements new strategies on countering corruption, and new leadership is installed at the U.S. Department of Justice and […]

White Collar Defense & Investigations New Guidance on Speaker Programs Highlights Potential Compliance Risks for Pharmaceutical Companies and Health Care Professionals

by Vince Farhat and Lena Streisand The PhRMA Code on Interactions with Health Care Professionals (PhRMA Code or Code) is a voluntary code of ethics covering pharmaceutical company dealings with health care professionals (HCPs). Signatory companies submit annual certifications attesting that they have policies and procedures in place to foster compliance with the Code. First […]

White Collar Defense & Investigations FinCEN Seeks Comments on Ownership Disclosure Requirements in New Federal Anti-Money Laundering Law

On April 1, 2021, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published an advance notice of proposed rulemaking giving companies and individuals the chance to comment on the new beneficial ownership disclosure requirements contained in the recently-enacted Corporate Transparency Act (“CTA”), which is part of the Anti-Money Laundering Act of 2020 (“AMLA”) included in […]

White Collar Defense & Investigations California Targets Financial Services Industry With New Enforcement Agency

California Targets Financial Services Industry With New Enforcement Agency by Vince Farhat After months of back and forth, Governor Gavin Newsom’s state version of the federal Consumer Financial Protection Bureau, often referred to as California’s “mini-CFPB,” is finally a reality. In late August, the California Legislature passed AB 1864, which creates the Department of Financial […]