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Compliance Counseling

WMH lawyers have counseled corporate clients on an array of regulatory and compliance issues.  We have designed and implemented compliance programs addressing anti-money laundering, Foreign Corrupt Practices Act (FCPA), antitrust, political contributions, and other regulatory issues.

Representative Cases

  • Currently serve as Member of Independent Monitor of General Motors, appointed in October 2015 by Department of Justice pursuant to deferred prosecution agreement arising from GM’s ignition-switch failure issue.
  • Helped evaluate compliance and regulatory issues at troubled subsidiary of Fortune 500 Company, which manufactured PTH assays, resulting in action by Board of Directors to close subsidiary.
  • In context of investigation of private health-care company brought by New York Attorney General, evaluated and revised compliance programs for billings related to nurses and home health aides.
  • In context of Department of Justice investigation over suspected collusion between managed care companies, devised enhancements to compliance program of Fortune 100 Company.
  • Created and implemented program for FCPA compliance for global shipping company.
  • Created and helped implement program for FCPA compliance for major mining corporation.
  • Created and helped implement compliance program for political contributions for national liquor distribution company.
  • Represented global auto parts manufacturer in investigation by Department of Justice’s Antitrust Division into suspected price-fixing and bid-rigging, and, after completing investigation, drafted and helped implement enhanced compliance programs.
  • Represented major sporting goods retailer in connection with investigation by New York City District Attorney concerning sales of allegedly illegal knives, and, after completing investigation, drafted and helped implement enhanced compliance programs.
  • Represented global retailer in connection with District Attorney’s investigation of events leading to alleged trampling death at “Black Friday” sales event, and, after completing investigation, drafted and helped implement enhanced compliance programs for crowd control.
  • Represented real estate developer in connection with lawsuit filed by New York Attorney General’s Office concerning illegal evictions, and, as part of settlement agreement, drafted new company-wide policies and procedures and compliance plan, in collaboration with an appointed monitor.
  • One of our attorneys previously served on Independent Monitorship team appointed pursuant to deferred prosecution agreement between Department of Justice and international medical device manufacturer to resolve claims in connection with Anti-Kickback Statute and False Claims Act. As part of monitorship, the WMH attorney helped oversee implementation of new corporate compliance procedures, including by conducting top-to-bottom review of medical device manufacturer’s compliance department; providing recommendations; and drafting and implementing new policies, certifications, and consulting agreements.
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