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Relator Not Entitled to a Portion of Funds Voluntarily Repaid by FCA Defendant
  • Sidley Austin LLP
  • USA
  • July 21 2016

The False Claims Act allows relators to share in a recovery even where the United States pursues an “alternative remedy” rather than direct FCA


New case on front-running
  • Sidley Austin LLP
  • USA
  • July 21 2016

The criminal complaint brought by the U.S. DOJ against currency traders marks another example of a “front running” case. In the complaint


Coscia gets three-year prison sentence for spoofing
  • Sidley Austin LLP
  • USA
  • July 18 2016

On July 13, convicted commodities trader Michael Coscia was sentenced to three years in prison and two years of supervised release for spoofing and


New York Banking Regulator Issues Anti-Money Laundering Rules for Transaction Monitoring and Filtering Programs
  • Sidley Austin LLP
  • USA
  • July 7 2016

On June 30, 2016, the New York State Department of Financial Services (NYDFS) issued a final regulation (the Final Rule) that sets forth the minimum


D.C. Circuit Affirms Expansive Reading Of Public Disclosure Bar
  • Sidley Austin LLP
  • USA
  • July 5 2016

In a recent opinion by Judge Wilkins, the D.C. Circuit affirmed the dismissal of a qui tam action against Phillip Morris, United States ex rel Oliver


Medical Device Company Settles with OFAC on Iran Sanctions Charges
  • Sidley Austin LLP
  • Iran, USA
  • June 28 2016

After an uncharacteristic lull in the release of enforcement notices, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC


Stumbling Blocks To DOJ’s Focus On Individuals: Jury Acquits Former Warner Chilcott Exec, Confirms AKS Cannot Be Used To Attack Efforts Merely To Build Relationships
  • Sidley Austin LLP
  • USA
  • June 17 2016

In the wake of Warner Chilcott’s civil settlement and guilty plea last fall, DOJ made headlines with the indictment of former Warner Chilcott


Final rule on customer due diligence requirements issued
  • Sidley Austin LLP
  • USA
  • June 17 2016

On May 11 2016 the Financial Crimes Enforcement Network (FinCEN) published a final rule that formalises new and existing customer due diligence (CDD


Securities class actions in the life sciences sector
  • Sidley Austin LLP
  • USA
  • June 10 2016

Before analyzing these decisions, we briefly take note of United States Supreme Court activity in the area of securities litigation generally in 2015


Sidley Perspectives on M&A and Corporate Governance - June 2016
  • Sidley Austin LLP
  • USA
  • June 10 2016

The exposure of corporate directors to shareholder derivative suits relating to their obligations to provide "risk oversight" to the company may turn