Healthcare fraud continues to plague the industry – each year Medicare and Medicaid suffer over $100 billion in losses from fraudsters. Prosecuting fraud cases in the healthcare industry is like shooting fish in a barrel – there are an infinite number of targets. To publicize its efforts, each year, DOJ executes multiple nationwide takedowns, rounding up healthcare fraudsters across the nation. In its most recent...
Corporate compliance programs in the healthcare industry include many of the same elements that we are all familiar with – risk assessments, code of ethics, written policies and procedures, comprehensive training requirements, confidential reporting and investigation systems to address employee concerns, gifts, meals, grants, and medical education programs, and audit and review processes to maintain a continuous improvement program. Aside from this standard list of...
If you are a compliance officer for a healthcare provider (e.g. hospital, HMO, skilled nursing facility, hospice center), you must sometimes feel that no one understands or feels your pain. When you consider the number and extent of risks, it can be mind-boggling. I am sure there are times that compliance officers in the healthcare industry look wistfully or even with envy at a compliance...
Corporate governance frameworks seek to maximize management efficiency, risk mitigation, and business success. The most important tool for accomplishing these objectives is straightforward – a Culture of Ethics and Compliance. Business leaders have found religion and started to embrace a culture of ethics as an engine for success. Compliance professionals have been singing this song for years. Suddenly, corporate leaders are starting to ask questions...
Volkov Law partner Jessica Sanderson will be speaking at next week’s “Third-Party Risk Management Oversight Summit,” hosted by Compliance Week in Atlanta. There is still time to register! Jessica will be moderating a panel on Tuesday, June 27, 3:20-4:10pm discussing, “Best Practices to Ensure Sanctions Compliance,” and will be a panelist on Wednesday, June 28, 11:20am-12:20pm discussing “The Ins and Outs of Third-Party Compliance Audits.”...
OFAC continues its enforcement push. At the same time, OFAC is managing a complex, global set of sanctions against Russia. DOJ has promised to increase prosecution of global banks for sanctions violations. Meanwhile, OFAC reached another settlement with Swedbank Latvia AS (“Swedbank Latvia”), which is a subsidiary of “Swedbank AB”, a global bank headquartered in Stockholm, Sweden. Swedbank Latvia agreed to pay $3.43 million to...
With the recent release of ChatGPT, we are witnessing the exponential adoption of a new technology, new “large language models” (LLMs) that without question will transform society. It reminds me of the famous computer character, “Hal,” from 2001 Space Odyssey. We all recall the introduction of computers, the first use of browsers, and the famous dial-access to AOL. Within years, the “dot.com” explosion occurred. We...
Over the last year, ESG has become a political football as state actors have passed legislation to prevent state pensions and other institutions from weighing ESG factors in investment decisions. These prohibitions have extended to proxy issues cited by proxy advisors to state and local pensions and other funds. These efforts, however, have done little to stem the importance of ESG to shareholders, regulators, and...
Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for a posting on new guidance concerning Iranian unmanned aerial vehicles (“UAVs”). Alex can be reached at [email protected]. In a relatively rare move for four (4) Cabinet-level Departments, the U.S. Departments of Commerce, Justice, State and Treasury issued an advisory notice on June 9, 2023, aimed specifically at reminding industry of their obligations vis-a-vis...
Matt Stankiewicz, Partner at The Volkov Law Group, joins us for another post detailing the SEC’s suit against Coinbase. Matt can be contacted at [email protected]. On June 6, 2023, the U.S. Securities and Exchange Commission (“SEC”) officially filed suit against Coinbase, Inc. (“Coinbase”) alleging the company operated as an unregistered securities exchange, broker, and clearing agency. The SEC is also suing Coinbase for failing to...
