An effective anti-corruption program is important for any company covered by Foreign Corrupt Practices Act (“FCPA”), which bars American companies from bribing officials overseas.

The World Bank and its partners have released the “Anti-Corruption Ethics and Compliance Handbook for Business,” billed as a new resource developed by companies, for companies. (Available at http://www.oecd.org/g20/topics/anti-corruption/anti-corruption-ethics-and-compliance-handbook-for-business.htm

Continuing a trend we reported in January 2014, the U.S. Department of Justice announced another multi-million dollar settlement of alleged False Claims Act (“FCA”) violations.  In this case, Halifax Hospital Medical Center and Halifax Staffing, Inc. (collectively “Halifax”) agreed to pay $85 million to resolve allegations that they violated the False Claims Act by submitting

Hospice of the Comforter, Inc. (HOTCI) agreed to pay $3 million to resolve allegations that it violated the False Claims Act (FCA) by submitting false claims to the Medicare program for hospice services provided to patients who were not eligible for the Medicare hospice benefit.  HOTCI did not admit any liability in the settlement.  The

A federal court ordered Tuomey Healthcare System to pay $237,454,195 after a jury found that it had violated the Stark Law (restricting physician referrals and payments) and the False Claims Act (FCA) when it submitted 21,730 false claims involving physicians with whom it had financial relationships that violated the Stark Law.  United States ex rel.

On October 1, the Securities and Exchange Commission (SEC) announced that an unidentified whistleblower, “who voluntarily provided original information” to the SEC “that led to the successful enforcement” action against an undisclosed company, has been awarded a record $14 million.  According to the SEC, the award “recognizes the significance of the information that the Claimant provided to the Commission, the assistance the Claimant provided in the Commission action, and the law enforcement interest in deterring violations by granting awards.”

This is the third such award the SEC has made under the whistleblower provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (DFA) since the statute’s passage in 2010.  The others were in the amounts of $50,000 and a little more than $25,000.

The latest record award is no surprise to employers and their lawyers who have been monitoring the SEC’s actions under the DFA’s “bounty” provisions.
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