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White Collar + Fraud + Investigations + Compliance

Posts from July 2023.

On July 26, 2023, the U.S. Department of Justice, National Security Division (“DOJ NSD”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued the second-ever Tri-Seal Compliance Note (the “Note”). This Note discusses Voluntary Self-Disclosure of Potential Violations and discusses each agency’s aligned expectations for companies that discover potential violations of any administrative or criminal violations of sanctions and export controls, including expectations for prompt disclosure and remediation of such violations. The agencies collectively stress the important role that private sector businesses play in identifying threats from malicious actors and foreign adversaries seeking to subvert the U.S. financial system or access sensitive U.S. technologies or goods.

On Friday, the DOJ announced that Booz Allen Hamilton Holding Corporation (“Booz Allen”) agreed to pay the United States $377,453,150 to resolve allegations that it violated the False Claims Act by improperly billing commercial and international costs to its government contracts. Notably, the settlement resolves allegations that for ten years, from 2011 to 2021, Booz Allen improperly charged indirect costs to its government contracts and subcontracts that should have been billed to commercial and international contracts under cost accounting standards. 

On Friday, July 14th, the DOJ announced its settlement with NextGen Healthcare (“NextGen”), an electronic health record technology vendor. NextGen agreed to pay $31 million to resolve allegations that it violated the False Claims Act by misrepresenting the capabilities of certain versions of its software and, separately, providing unlawful remuneration to its users to induce them to recommend NextGen’s software.

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