The New Administrative False Claims Act Enhances Federal Agencies’ Power to Combat Fraud

The Administrative False Claims Act (“AFCA”), previously known as the Program Fraud Civil Remedies Act of 1986 (“PFCRA”) is an infrequently used, but related counterpart to the more well-known False Claims Act (“FCA”). The FCA is a widely used tool by the Department of Justice (“DOJ”) to prosecute false claims and statements in federal courts,…

CORPORATE TRANSPARENCY ACT UPDATE: FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Persons and U.S. Entities

On March 21, 2025, FinCEN announced the release of a new interim final rule that removes the beneficial ownership reporting requirements for companies formed in the U.S. and U.S. persons under the CTA.  On March 26, 2025, the new interim final rule was published in the Federal Register and FinCEN published a Q&A offering additional…

CORPORATE TRANSPARENCY ACT UPDATE: U.S. Department of Treasury Suspends Enforcement of the CTA Against U.S. Citizens and Domestic Reporting Companies

On March 2, 2025, the U.S. Department of Treasury announced that it will not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, and that it will not enforce any penalties or fines against U.S. Citizens or domestic reporting companies or their beneficial owners after the…

CORPORATE TRANSPARENCY ACT (“CTA”) UPDATE: The CTA Reporting Requirements Are Back Once Again

The last remaining preliminary injunction blocking enforcement of the CTA on a nationwide basis has now been lifted and the CTA has been reinstated nationwide.  On February 17, 2025, in Smith v. U.S. Department of Treasury, a federal judge in the United States District Court for the Eastern District of Texas issued an order staying…

NEW CORPORATE TRANSPARENCY ACT UPDATE: Supreme Court of the United States Stays the Preliminary Injunction Blocking Enforcement of the CTA

On January 23, 2025, the Supreme Court of the United States issued a stay on the preliminary injunction that temporarily blocked enforcement of the Corporate Transparency Act (“CTA”) and its reporting rule on a nationwide basis.  This stay will remain in effect until the U.S. Court of Appeals for the Fifth Circuit renders a decision…

Are you Checking the PMP Before Prescribing? Pharmacy Board Audits of PMP Data

The Arizona Controlled Substances Prescription Monitoring Program (“PMP”) was established in 2007 and provides the State of Arizona with a central database to track the dispensing of controlled substances.  The PMP is designed to assist providers in making better-informed decisions and help “prevent the diversion and misuse of controlled substances at the provider, pharmacy, and…