White Collar Crime & Internal Investigations Blog

Category Archives: Internal Investigations

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White Collar – Corporate Settlements Continue to Grow, But Do They Produce Justice?

By Rodger A. Heaton on Posted in Healthcare Fraud, Internal Investigations, Sentencing, U.S. Attorney's Office

Deferred and nondeferred prosecution agreements with the federal government hit an all-time record in 2012 — approximately $9 billion. This was a 50 percent increase over the previous record year — 2006 — and nearly triple the recoveries in 2011. It is fair to conclude that the U.S. Department of Justice is aggressively seeking substantial financial penalties… Continue Reading

FY 2013 Federal Health Care Fraud Enforcement Priorities

By Rodger A. Heaton on Posted in Healthcare Fraud, Internal Investigations

My learned colleague, Lee Smith, focused on the increasing privatization of prosecutorial behavior in his recent post to this blog. Companies in highly regulated industries are well-versed in the myriad ways of protecting corporate interests, including by being willing to proactively excise corporate actors who are (or appear to be) connected to conduct that may… Continue Reading

The Hard Choice: To Hunker Down or Not

By L. Lee Smith on Posted in Internal Investigations

Every person or organization accused of wrongdoing is faced with a hard choice: (1) hunker down, hope it goes away, and if it doesn’t, deny and make them prove guilt; or (2) investigate the allegation and assemble the facts to defend or otherwise resolve. I can’t say that I’ve never seen the first option succeed…. Continue Reading

Pfizer Joins the List of Recent Large FCPA Settlements

By Brian Zeeck on Posted in Foreign Corrupt Practices Act, Internal Investigations, Securities Fraud

Yesterday the U.S. Attorney’s office filed an Information and deferred prosecution agreement against Pfizer H.C.P. Corp., a subsidiary of Pfizer Inc.  The deferred prosecution agreement is the result of a settlement reached by Pfizer H.C.P. with the United States relating to identified Foreign Corrupt Practices Act (“FCPA”) violations. Following what the Department of Justice has… Continue Reading

Building Credibility with the Government During an Investigation

By Rodger A. Heaton on Posted in Foreign Corrupt Practices Act, Internal Investigations

Catherine Dunn recently detailed several ways to build credibility with the Government during FCPA investigations, in the May 25, 2012 issue of Corporate Counsel, an online newsletter.  It’s a useful reminder of concepts that would benefit defense counsel in any white collar investigation that involves complex and substantial document collection and production to the government…. Continue Reading

CMS Issues Proposed Rules on Reporting and Returning of Overpayments Under Medicare

By Daniel Purdom on Posted in False Claims Act, Healthcare Fraud, Internal Investigations

The Centers for Medicare and Medicaid Services (CMS) recently issued its Proposed Rules for implementing provisions of the Patient Protection and Affordable Care Act (Act) on reporting and returning overpayments made under Medicare. The Act made a number of changes to Medicare that enhanced the program’s ability to recover overpayments and combat fraud, waste and… Continue Reading