SEC Ratchets Up Enforcement Against Attorneys in Microcap Space

Introduction Earlier this year, SEC Chairman Jay Clayton fired a warning shot across the bow of practicing securities attorneys: “act responsibly and hold [yourselves] to high standards.” Chairman Clayton specifically called out members of the securities bar advising clients on initial coin offerings (ICOs) that were not being registered with the SEC under the federal

2016 HIPAA Settlements Demonstrate HIPAA Compliance Challenges in a Mobile Society

The U.S. Department of Health and Human Services, Office for Civil Rights (“OCR”) has been actively enforcing the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) in 2016. As of August, covered entities and business associates (the organizations who are subject to HIPAA) have paid OCR more than $20 million to resolve allegations of

SCOTUS Raises the Bar on Materiality in False Claims Act Lawsuits

FCA

The implied false certification theory of liability under the False Claims Act (FCA) is premised on the notion that a person who does business with the federal government, by the very act of submitting a claim for payment, has impliedly certified compliance with the often numerous statutes, regulations, and contract terms that govern the contractual