Congress passed the Corporate Transparency Act of 2021 (CTA) as part of the Anti-Money Laundering Act of 2020 (AMLA) included in the National Defense Authorization Act (NDAA). The CTA created a beneficial ownership registry within the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). On September 29, 2022, FinCEN issued a final rule […]
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). […]
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 […]
by Vince Farhat and Lena Streisand Deputy Attorney General Lisa O. Monaco recently announced new policies targeting corporate white collar crime and reversing Trump-era guidelines deemed too lenient by the current leadership at the U.S. Department of Justice (“DOJ”). In an October 28, 2021 address to the American Bar Association’s National Institute on White Collar […]
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 […]
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 […]
An article by Vince Farhat titled “Cyber Attacks: Prevention and Proactive Responses” was published by Practical Law in May 2017. It was updated and republished by Practical Law in March 2021.
An article by Vince Farhat titled “Current Trends in CARES Act Tax Enforcement” was published by Tax Notes Federal on November 2, 2020. Read the article here, which is reprinted with permission from Tax Notes.
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 […]
We live in unprecedented times. Never before in modern history has the United States voluntarily shut-down its entire national economy in order to stop a virus pandemic. Payrolls have dropped by more than 21 million workers, wiping-out a decade of job gains. New orders, production, hiring, and new exports all fell again in May. As […]