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,…
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…
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…
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…
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…
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…
The materials provided in this website are for informational purposes only and are not for the purpose of providing legal advice. Transmission of information from the ML website is not intended to create, and its receipt by you does not create an attorney-client relationship with ML or any of its individual attorneys or personnel.
If you elect to communicate with anyone at ML through this website, or otherwise, in connection with a matter for which we do not already represent you, your communication can not be treated as privileged or confidential. Do not transmit any information about any matter (and particularly not information you regard as confidential) that may involve you until ML has agreed to represent you, and you have received confirmation of that fact in the form of a written engagement letter.