Building windows

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 The Next Wave of CARES Act Enforcement: Paycheck Protection Program Civil Fraud Investigations

The March 2020 Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) created enormous incentives for companies to apply for economic stimulus funding and grants to alleviate the devastating economic impacts from the worldwide pandemic. Until recently, the U.S. Department of Justice (“DOJ”) focused mainly on filing criminal actions against individuals who allegedly committed fraud […]

White Collar Defense & Investigations White Collar Enforcement Forecast: What to Expect in 2021

Changes in administrations often bring changes in law enforcement priorities. Whereas fines and prosecutions of white collar offenses declined under the previous administration, we can expect increased white collar enforcement under the Biden administration as new federal anti-money laundering laws take effect and new leadership is installed at the U.S. Department of Justice and other […]