False Claims Act: Implied Certification Theory
Readers of this blog may recall a piece in which we discussed a New Jersey State law known as Daniel’s Law and Atlas Data Privacy Corporation (“Atlas Data”), a consumer data protection company. Shortly after Daniel’s Law was...more
The Committee on Foreign Investment in the United States (CFIUS) released its statutorily mandated annual report to congress last month. While the report itself highlights several notable developments in 2023 (New Zealand and...more
United States Environmental Protection Agency (“EPA”) and East Side Plating, Inc. (“East Side”) entered into a March 13th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Clean Air Act...more
The United States Environmental Protection Agency (“EPA”) and Heritage Training and Shooting Center, LLC (“Heritage”) entered into a January 6th Expedited Settlement Agreement (“ESA”) addressing alleged violations of the...more
The U.S. Department of Health and Human Services Office for Civil Rights (OCR) continues its enforcement activities to emphasize compliance with the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule’s...more
On January 21, 2021, President Biden signed an Executive Order on Promoting COVID-19 Safety in Domestic and International Travel, which mandated mask wearing on all commercial aircraft. In addition, all domestic United...more
Last week, the Illinois Appellate Court issued three separate opinions addressing the scope of the Illinois Freedom of Information Act (FOIA). The opinions provide additional guidance related to what constitutes a reasonable...more
- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. - CEO leadership helps set an example for lower management and company...more
The Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services imposed a $2,154,000 civil money penalty (CMP) against Jackson Health System (JHS) for violations of the Health Insurance Portability and...more
On August 26, 2019, the Transportation Security Administration (TSA) enacted its new Action Plan Program. The Action Plan Program "provides an opportunity for eligible parties and TSA to discuss and reach an agreement on...more
As the old adage provides – better late than never. (Same applies for my somewhat tardy posting on this case). Telefônica Brasil settled FCPA violations with the SEC for a pretty penny — $4.125 million in civil penalties...more
The United States Environmental Protection Agency (“EPA”) and Lee Hi Travel Plaza (“Lee Hi”) entered into a September 6th Consent Agreement (“CA”) addressing alleged violations of the Resource Conservation and Recovery Act...more
The United States Environmental Protection Agency (“EPA”) entered into an Expedited Settlement Agreement (“ESA”) with First Group America, Inc., d/b/a First Student, Inc. and First Transit, Inc. See Docket No....more
“Don’t make promises that you don’t intend to keep” is an admonishment received by every child and delivered by every parent. This pithy maxim is equally applicable to consent orders entered into with regulatory authorities....more
The U.S. Consumer Product Safety Commission (CPSC) is set to announce yet another civil penalty settlement. Sunbeam Products d/b/a Jarden Consumer Solutions (Sunbeam or the Company) has agreed to pay a $4.5 million civil...more