By Mani Dabiri | Published May 21, 2019 | Posted in Civil Business Litigation and Investigations, Federal and State Criminal Defense, Government Subpoenas and Investigations, White-Collar and Regulatory Defense | Tagged Tags: antikickbackstatutes, briberyandcorruption, departmentofjustice, DOJ, exclusionordebarment, healthandhumanservices, healthcare, HHS, medicareandmedicaid, moneylaundering |
Iran Sanctions Look to Snap Back
By now you’ve heard the news, and it’s pretty much what it sounds like. Following a wind-down period of 90 or 180 days, the U.S. government will restore the economic sanctions that it lifted under the 2015 nuclear deal. These sanctions generally affect foreign businesses who do business with Iran. After the wind-down periods, they Read More
Read MoreNew Year’s Resolutions
Speaking of compliance, here are two businesses that ended the year resolving charges they violated U.S. trade sanctions by dealing with blocked countries, people, or entities. Both cases show how the government enforces its sanctions regime, and they illustrate how an ounce of prevention can beat a pound of cure. Both cases were brought by the Office of Read More
Read MoreSEC Chair Offers Advice on Bitcoin and Its Ilk
This week, the chair of the U.S. Securities and Exchange Commission weighed in on crypto-currencies as well as ICOs or initial coin offerings. With the price of bitcoin nearing $20,000, it probably comes at the right time. You may have been wondering yourself: What are the rules for this stuff? Are they being followed? And what are the risks Read More
Read MoreAnother Massive Medicare-Fraud Roundup
In case you missed it, two weeks ago, the federal Medicare Fraud Strike Force announced a nationwide sweep that ensnared 243 people for their alleged participation in fraudulent schemes to bill Medicare over $700 million. The individual cases are not all related, but the coordinated takedown was the largest we’ve seen so far—both in the number of targets and in the Read More
Read MoreAbuses of Asset Forfeiture Appear to Abound
In an op-ed piece from the Washington Post, two former senior Justice Department officials have called for an end to the asset-forfeiture program they helped create for the federal government. John Yoder and Brad Cates were each, in turn, director of the Department’s Asset Forfeiture Office from 1983 to 1989. They say federal asset forfeiture was conceived to combat drug Read More
Read MoreTrade-Based Money Laundering is Like a Box of Chocolates
In the cat-and-mouse game of money laundering, which we earlier covered here (in an overview) and here (about what can go wrong), some of the more sophisticated schemes involve trade-based money laundering, which embeds the proceeds of criminal activity in legitimate cross-border commerce. Take any good that is imported or exported around the world, and you can use the trade in that good to launder money by manipulating or misrepresenting price, quality, Read More
Read MoreWhen Money-Laundering Laws Become “Smurfin’ Ridiculous”
While we’re on the subject of money laundering, let’s talk about “smurfing.” That’s slang for the term “structuring,” which refers to the purposeful act of breaking up larger financial transactions into smaller amounts in order to avoid federal reporting requirements. For example, the Bank Secrecy Act requires banks to report any deposits, withdrawals, or transfers of more than $10,000. Read More
Read MoreCleanliness is Next to Godliness for George, Tom, Abe, Alex, Andy, Ulysses, and Ben
In common parlance, money laundering is the process of taking illegally-gained, “dirty” money and making it appear legal or “clean.” Who needs to wash money? A classic case is the drug dealer who’s sitting on a pile of cash but can’t very well explain where he got it from. The same concept, however, applies to other unlawful activity like financial frauds, computer crimes, alien smuggling, Read More
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