The Department of Justice-Criminal Division recently updated its internal guidance to federal prosecutors for evaluating corporate compliance programs. Despite the lack of major substantive changes, the updated guidance encourages prosecutors to take the risk profile of corporations into account when evaluating its compliance programs.
The False Claims Act (FCA) has long been a powerful tool for the federal government to generate large recoveries from government contractors, including companies in the healthcare industry. In fiscal year 2017 alone, the US Department of Justice (DOJ) recovered more than $3.7 billion in settlements and judgments in civil cases brought under the FCA.
When last we checked in with our intrepid railroad, legendary railroader E. Hunter Harrison was leading the company through rapid and tumultuous change. Trumpeting his famed ‘Precision Railroading’ and driving CSX’s stock up more than $10B in value, while overseeing rapid consolidation and layoffs, at least shareholders were enjoying the fruits of activist investing. Looming