Review some areas of potential fraud of which a health care company should be aware to stay compliant and off the DOJ’s radar.
Is the cost to U.S. business justified by the benefits of sanctions? In other words, are U.S. economic sanctions programs effective in achieving their stated goals?
Although litigation over anonymous online speakers is unlikely to be settled by this controversy alone, there are reasons to expect (or hope) that prosecutors will pursue other avenues to locate persons with knowledge of corporate fraud, and that the compelled outing of commentators might remain an unusual last resort.
If the widely-reported allegations flowing from the #MeToo and #TimesUp movements weren’t enough of a wake-up call for New York corporations, the New York Attorney General has issued a sharp warning about systemic workplace sexual harassment that all organizations doing business in New York state, and their principals, directors, managers and employees, would be wise to heed.
Companies that wait to discover potential misconduct and then conduct a thorough and comprehensive internal investigation before taking remedial action will likely lose out on substantial benefits, including possible declination of prosecution.
As UK courts reshape the landscape of privilege law in the internal investigations context, a recent decision offers guidance but not clarity.