Federal Authorities Have Their Eyes on Treatment Facilities, Sober Living Home Operators and Marketers, Especially in Orange County

Federal prosecutors are aggressively targeting the substance use disorder treatment space—an industry that some believe has been permeated with fraud and abuse. This is particularly the case in Orange County, California, referred to by some as part of the “Rehab Riviera” on account of the dense concentration of treatment facilities and sober living homes in Costa Mesa, Laguna Beach and San Juan Capistrano.

Just last week, on November 15, a marketer pleaded guilty in Orange County federal court to accepting nearly $2 million in kickback payments in return for referring patients to treatment facilities. And, by all indications, further indictments and charges are coming. (Read More)  

Binance De-Platforms Suex Exchange Amid Groundbreaking Sanctions: Potential New Standards in Cryptocurrency Compliance

Last month, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied sanctions against Russian-based cryptocurrency exchange Suex. This move represents the first time the U.S. has sanctioned a digital currency exchange, signaling a major shift for cryptocurrency exchanges and their potential exposure to liability.

The news gets even worse for Suex. Around the same time that OFAC announced the sanctions, cryptocurrency exchange Binance announced that its compliance program had identified issues with Suex, de-platformed the exchange, and shared information from its investigation with law enforcement. Binance’s success may set a new standard for digital asset compliance programs, but time will tell whether it has set a new gold standard or will become the bare minimum. (Read More)

5 Corporate Takeaways from the Facebook Whistleblower Hearing

Stakeholders at businesses worldwide listened attentively last week as a former Facebook product manager testified before a Senate subcommittee about, among other things, the company’s purported knowledge of Instagram’s impact on young users of the app. Frances Haugen, who worked on issues regarding civic integrity while at Facebook, also released thousands of pages of research and internal documentation suggesting Facebook knew about an array of problems associated with Instagram, including its allegedly toxic effect on teens. (Read More)

SEC v. BitConnect: New Technology, Same Old Financial Fraud

Blockchain technology is often touted for its enormous potential to revolutionize many aspects of the financial system. This relatively new technology, however, does nothing to eliminate would-be criminals from leveraging age-old fraud schemes. The SEC’s recent case against BitConnect bears this out. The proceeding also demonstrates that the federal government maintains a strong interest in rooting out old-fashioned fraud, even in the digital asset space. (Read More)

Quick Resource Guide to Foreign Corrupt Practices Act (FCPA) for Turkish Companies

Lawyers from Michelman & Robinson and Cetinkaya have authored a recently published white paper titled “FCPA for Turkish Companies.” This is a comprehensive resource guide to the Foreign Corrupt Practices Act and its application in Turkey. You can read the white paper here.

The Anti-Money Laundering Act of 2020: New Rules for Your Business

Early this year, the U.S. Congress enacted the National Defense Authorization Act, which included the Anti-Money Laundering Act of 2020 (AMLA or the Act). With the passage of the dramatic new set of laws came a broad range of fresh anti-money laundering obligations for banks and other financial institutions, certain private investment structures, and even federal regulators.

In the wake of this relatively recent legislation, several questions have arisen, especially with regard to compliance and the Act’s operational impacts. Many of the more significant, top-line issues are addressed here. (Read More)