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Sidley Austin LLP | USA | 19 Apr 2019

District Court Held that Government Must Produce Factual Basis For Allegations of Below-Fair-Market-Value Transfers

Earlier this month, in a FCA case in which the Government intervened, the United States District Court for the District of Minnesota held that the


Sidley Austin LLP | USA | 19 Mar 2019

Third Circuit Finds Individual Ownership Interest in Corporation Not Required for FCA Liability and Unsworn Testimony Insufficient to Create a Material Issue of Fact

On March 14, 2018, the Third Circuit affirmed in part and vacated in part a district court ruling granting the United States’ motion for summary


Sidley Austin LLP | USA | 11 Mar 2019

Court Dismisses DOJ’s Complaint against Pharmacy and Private Equity Fund, But Permits Re-Pleading

As we previously reported here and here, DOJ is pursuing a compounding pharmacy and its private equity fund owner alleging the pharmacy filed claims


Sidley Austin LLP | United Kingdom | 28 Feb 2019

FCA Publishes Wholesale Banks and Asset Management Cyber Multi-Firm Review Findings

The UK Financial Conduct Authority (“FCA”) has carried out a multi-firm review of cybersecurity practices with a sample of 20 firms in the wholesale


Sidley Austin LLP | USA | 16 Jul 2018

LIBOR’s Final Chapter: Practical Considerations for Buy Side Market Participants

Background LIBOR (London Interbank Offered Rate) and other interbank offered rates (IBORs) are interest rate benchmarks that are widely used for many


Sidley Austin LLP | USA | 11 May 2018

DOJ Defends Use of Statistical Sampling To Prove FCA Liability

In a case in which it chose not to intervene, DOJ has stepped in to defend the relator’s attempt to use statistical sampling to prove FCA liability


Sidley Austin LLP | Singapore, United Kingdom, European Union, etc. | 6 Sep 2017

FinTech and Regulatory Sandboxes in the UK, Hong Kong and Singapore

As the FinTech industry continues to expand, regulators around the globe are starting to react. The past 18 months have seen the emergence of a new


Sidley Austin LLP | USA | 12 Jun 2017

Eleventh Circuit Rules That Reasonable Interpretations of Ambiguous Regulations Can Trigger FCA Liability

Noncompliance with ambiguous regulations often presents a weak case for an FCA suit. A growing number of courts (as discussed here and here) have


Sidley Austin LLP | United Kingdom, European Union | 30 May 2017

Money Laundering Regulations 2017: Preparing for the UK’s New Customer Due Diligence Regime

The UK is amending its requirements as to customer due diligence (and related matters) in the context of antimoney-laundering and counter-financing


Sidley Austin LLP | USA | 6 Feb 2017

Court Rejects DOJ Attempt to Insulate Prior Payment Practices from Discovery

Historical government payment practices have gained new importance following the Supreme Court's guidance in Escobar that such practices can preclude

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