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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.
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 […]
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 […]
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 […]
With the passage of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), the federal government created significant incentives for companies to apply for economic stimulus funding and grants to alleviate the devastating economic impacts from the worldwide COVID-19 pandemic. With upwards to $2 trillion in government aid expected to be disbursed, federal and […]
An article by Vince Farhat titled “Impact of Justices’ Excessive Fines Ruling Will Vary By State” was published by Law360.
