One of the benefits of old(er) age is perspective and experience. (As we age, we have to find the positive reasons to tout). If there is one thing (of many) the compliance profession has demonstrated, it is that compliance professionals are nimble. It comes with the territory. Building and maintaining a compliance program, requires compliance professionals to adjust their focus and prioritize resources and time...
As if corporate healthcare businesses needed an enforcement reminder, DOJ recently announced a settlement with Cigna Group for $172 million to resolve claims that Cigna exaggerated patient illnesses to extract more money from the Medicare Advantage Program. Under the Medicare Advantage (MA) Program, also known as Medicare Part C, Medicare beneficiaries have the option of obtaining their Medicare-covered benefits through private insurance plans called MA...
Matt Stankiewicz, Partner at The Volkov Law Group PC, rejoins us for an important blog posting concerning OFAC’s recent relaxation of the Venezuela Sanctions Program. Matt can be reached at [email protected]. On October 18, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) took several steps to provide Venezuela with some limited relief from its sanctions. The relief includes General Licenses authorizing...
Daniela Melendez, an Associate at The Volkov Law Group, an Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoin us for another posting on DOJ’s recent modifications to its compliance requirements. Daniela can be reached at [email protected] and Alex can be reached at [email protected]. As The Volkov Law Group previously noted in the context of a blog post authored by Michael Volkov, the U.S....
I always welcome any chance to use references to The Mandalorian series on Disney (or Ashoka for that matter) in the compliance arena. My take on the issue of electronic communications and ephemeral messaging is rooted in practical, risk-based strategies to avoid potential legal consequences that appear to be steadily growing as DOJ and courts deal with the issues. So, “This is the Way,” at...
Just to play devil’s advocate (or perhaps to push my agenda), I have conflicting views on corporate use of ephemeral messaging applications. On the one hand, I understand the importance of managing electronics communications data, prioritizing the preservation of relevant data, and reducing attendant costs from managing ever-growing amounts of electronic data. On the other hand, as a former prosecutor and now defense counsel, I...
Honestly, I have been avoiding this topic since it presents a real morass of risks and potential traps for the unwary company and Chief Compliance and Chief Legal Officers. When I first examined the issue, I understood DOJ’s frustration. If bad actors can escape detection and subsequent punishment (internal or external) by using ephemeral messaging applications to delete illegal or improper communications, companies should simply...
I had the honor of appearing on GRIP, Global Relay’s podcast, with long-time colleague and friend, Julie DiMauro, to discuss a range of related FCPA topics: You can listen to our discussion here. You can listen to our discussion here.
Sam Finkelstein rejoins us for a posting on OFAC’s recent enforcement steps and guidance on Russian Oil Sanctions and the Maritime Industry. Sam can be reached at [email protected]. It looks like the days of Russia’s so-called “shadow fleet” are numbered. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced Thursday that it had imposed sanctions on two entities, and identified as...
Alex Cotoia, Regulatory Manager, and Daniela Melendez, an Associate at The Volkov Law Group, rejoin us for a joint posting reminding readers on the importance of addressing electronic communications preservation and management in this new age of rapid technological change. Alex can be reached at [email protected], and Daniela can be reached at [email protected]. One thing you can count on — change. Not that there is...
