In recent years, the Biden Administration has been vocal that combatting foreign public corruption is a key pillar of its national security efforts.[1] Consistent with those policy goals, on December 22, 2023, Congress passed the Foreign Extortion Prevention
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New York LLC Transparency Act Beneficial Ownership Reporting Requirements to Take Effect
On December 23, 2023, New York Governor Kathy Hochul signed the New York LLC Transparency Act (“NYLTA”), which requires LLCs to disclose beneficial ownership information (“BOI”) to the New York Department of State. Effective December 21, 2024, the NYLTA will…
1st Circuit Rejects Convicted Former Medical Device Executives’ Off-Label “Free Speech” Theory
A federal appeals court recently upheld misdemeanor convictions of two former Acclarent Inc. executives for commercially distributing an adulterated and misbranded medical device by misleading the U.S. Food and Drug Administration regarding the device’s intended use.
Read on for details…
Corporate Transparency Act: Three Updates for January 2024
RELATED UPDATE: Deputy Attorney General Monaco Announces New DOJ Whistleblower Program (March 8, 2024)
As of January 1, 2024, the Corporate Transparency Act (“CTA”) has gone into effect. Companies that may be Reporting Companies of Beneficial Ownership Information (“BOI”) should…
FinCEN Extends Time to File Beneficial Ownership Information for Entities Created After January 1, 2024
The Corporate Transparency Act (“CTA”) was enacted in 2021 as part of the Anti-Money Laundering Act of 2020. The CTA requires certain business entities (“Reporting Companies”) to report beneficial ownership information (“BOI”), and, for entities created or registered on or…
FinCEN Specifies When and How Reporting Companies May Use FinCEN Identifiers
The Corporate Transparency Act (“CTA”) was enacted in 2021 as part of the Anti-Money Laundering Act of 2020, requiring certain business entities (“Reporting Companies”) to report beneficial ownership information (“BOI”), and, for entities created or registered on or after January…
Lessons for Providers and Practice Entities: Ophthalmology Groups Pay Millions to Settle Co-Management, Optometrist Relationship Allegations
Two ophthalmology practice groups recently reached settlements with the U.S. government totaling nearly $20 million to resolve allegations that their third-party cataract arrangements violated several healthcare laws.
Read on to discover how the settlements offer guidance to vision providers with…
Beneficial Ownership Reporting Requirements under the Corporate Transparency Act
Corporate Transparency Act Beneficial Ownership Reporting Requirements to Take Effect
In 2021, the Corporate Transparency Act (“CTA”) was enacted as part of the Anti-Money Laundering Act of 2020, requiring certain business entities (“Reporting Companies”) to report beneficial ownership information (“BOI”)…
Economic Crime and Corporate Transparency Act Becomes Law: What Companies Need to Know
On 26 October 2023, the Economic Crime and Corporate Transparency Act received royal assent. The new law is designed to fight corruption, money laundering and fraud, and has major implications for businesses, including:
…
DOJ Announces Safe Harbor Policy for Mergers and Acquisitions
In the U.S. Department of Justice’s continuing efforts to incentivize voluntary disclosure of corporate misconduct, Deputy Attorney General Lisa Monaco announced the Criminal Division’s latest corporate self-disclosure policy this week, aimed at mergers and acquisitions specifically (remarks Here). Pursuant…