Recently by Paul B. Murphy
Department of Justice (DOJ)
Pushing Back on Piling On: Heaping regulatory penalties on businesses that plead guilty may not be the answer
“A slap-on-the-wrist culture.” This is how Senator Elizabeth Warren (D-Mass.), speaking publicly this spring, characterized recent decisions by the Department of Justice, the Securities and Exchange Commission and other regulators not to impose the most severe regulatory penalties...
Read MoreHealthcare
From Carrot to Stick?: Use of Self-Audits as Evidence Against Healthcare Entities in False Claims Act Cases
Introduction In recent years, many healthcare entities have invested tremendous resources into compliance programs. They have done so with the understanding that good faith compliance efforts – while by no means an absolute shield to enforcement actions under the False Claims Act (FCA)[1...
Read MoreWatching Your Step: Avoiding The Pitfalls And Perils Of Corporate Internal Investigations - Part II
To conduct a credible and accurate investigation, counsel should interview everyone with relevant information. When conducting interviews, however, the attorney must be mindful that an employee interview is a fact-finding exercise, not an opportunity to "woodshed" the witness into adopting a...
Read MoreCorporate Compliance - Law Firms Watching Your Step: Avoiding The Pitfalls And Perils Of Corporate Internal Investigations - Part I
Since the creation of the Corporate Fraud Task Force in July 2002, the United States Department of Justice and the other member agencies have worked feverishly to ferret out corporate crime and punish wrongdoers. The Task Force, in the three years following the announcement of its formation by...
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