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OGE Amends Executive Branch Ethics Program

Client Alert | less than 1 min read | 11.07.16

On November 2, 2016, the Office of Government Ethics issued a final rule amending the regulations setting forth the elements and procedures of the executive branch ethics program by defining and describing the executive branch ethics program, delineating the responsibilities of various government stakeholders, and enumerating key executive branch ethics procedures. Among the various amendments, which are detailed in our blog post, the final rule centralizes the procedures of the executive branch ethics program and modifies the procedures for the correction of agency noncompliance by outlining several remedial actions that may be taken.

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Client Alert | 4 min read | 04.16.26

ROI Tracking as Mens Rea? Novartis Ruling Reframes AKS Pleading Risk

Is evidence that a company tracked return on investment (ROI) for certain actions and expenses sufficient to prove mens rea and plead a violation of the federal Anti-Kickback Statute (AKS) with the requisite particularity? A recent decision in the U.S. District Court for the Southern District of New York (SDNY) suggests that it is....