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Steward Health Reportedly Under FCPA Investigation


As highlighted in this prior post, in 2018, Steward Health Care System LLC (a private hospital operator in the United States headquartered in Boston) “finalized a public-private partnership to deliver exceptional health care to the people of Malta. Steward, which is physician-led and the largest private hospital operator in the United States, is now the government of Malta’s health care partner and will run a number of public medical facilities in the country.” (See here). The public-private partnership “resulted from Steward’s purchase of Vitals Global Healthcare’s concessions to run facilities [in Malta] entrusted to it.”

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Assistant Chief Of The DOJ’s FCPA Unit Goes To FCPA Inc.


As sure as the sun rises in the east and dogs bark – and following a well traveled career path – the Assistant Chief of the DOJ’s FCPA Unit is joining a law firm for an FCPA practice.

According to this Akin Gump Strauss Hauer & Feld LLP release:

“Gerald Moody joins Akin from the U.S. Department of Justice (DOJ) Criminal Division’s Fraud Section, where he was an Assistant Chief of the Foreign Corrupt Practices Act (FCPA) Unit. During his time at the DOJ Fraud Section, Moody led or supervised more than 100 FCPA-related investigations. Moody coordinated regularly with counterparts at domestic and international law enforcement and regulatory agencies, including various U.S. Attorney’s Offices, the SEC, FinCEN and foreign authorities in the United Kingdom, Brazil, France, and Switzerland, among others.”

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Checking In On Joint Task Force Alpha


As highlighted in this prior post, in June 2021 U.S. Attorney General Merrick Garland “announced a series of steps that the Department of Justice is taking to address the threats posed by both corruption and by transnational human smuggling and trafficking networks” in Central America.

Through the establishment of so-called “Joint Task Force Alpha” the goal was “to enhance U.S. enforcement efforts against the most prolific and dangerous human smuggling and trafficking groups operating in Mexico and the Northern Triangle countries of Guatemala, El Salvador, and Honduras.”

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Interesting Issues To Ponder


Several notable Foreign Corrupt Practices Act enforcement actions have involved conduct in Haiti including U.S. v. Kay and U.S. v. Esquenazi.

The Esquenazi enforcement action concerned the telecommunications sector in Haiti.

Reading the news with “FCPA goggles” on is – for me – an occupational hazard of sorts.

So it was with a recent Wall Street Journal article titled “Amid Haiti’s Mayhem, Phones Keep Working.”

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