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Hot Off the Press: Revised DOJ Guidance for Corporate Compliance Programs

USA - June 4 2020 Earlier this week, on June 1, the Department of Justice published its latest version of “Evaluation of Corporate Compliance Programs.” Like the…

Jacqueline C. Wolff

Heightened Risk of Criminal and Civil Liability for Nursing Homes in the Time of COVID-19

USA - May 21 2020 Nursing homes and other post-acute healthcare providers have long been the focus of both Government Investigations and private plaintiffs focusing on…

Randi Seigel, Jacqueline C. Wolff, Molly Wyler

Best Practices to Navigate CARES Act Provider Relief Funding and Minimize False Claims Act Exposure

USA - May 7 2020 On April 10, the U.S. Department of Health and Human Services (HHS) announced the immediate distribution of the first $30 billion of the $100 billion…

Francis J. LaPallo, Melinda J. Dutton, Allison B. Orris

Bank Secrecy Act Compliance Issues for Small-Business Lending Under the CARES Act

USA - April 14 2020 With many banks and credit unions electing to limit Paycheck Protection Program (PPP) loans to existing customers, many nonbank lenders are…

Richard S. Hartunian, Charles E. Washburn, Jr., Scott M. Pearson, Jacqueline C. Wolff, Andrew Zimmitti

False Claims Act Liability for Lenders Participating in the CARES Act Paycheck Protection Program

USA - April 9 2020 Although federal regulators repeatedly have assured banks that they can make Paycheck Protection Program (“PPP”) loans without fear of later…

Richard S. Hartunian, June Kim, Scott M. Pearson, Jacqueline C. Wolff, Andrew Zimmitti