Compliance, Investigations & White Collar

Wendy and Jen Wreck the Movies: ‘Willy Wonka’ (1971) or You Got Your Kid in My Chocolate
January 30, 2024 | Jennifer F. Hillman | Wendy Hoey Sheinberg | Immigration | Employment & Labor | Corporate | Compliance, Investigations & White Collar

What Happened

Come on, you know what happened, right?

For those denied the joy of Roald Dahl and his take on bad parents, here is an overview.

Willy Wonka, the owner of Wonka’s Chocolates, is a unique and secretive chocolatier. Wonka’s Chocolates has one factory. Unlike other factories, no workers or visitors are seen entering

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Shapiro and Ullman Write for Nutrition Industry Executive on Counterfeiting
August 2, 2023 | Steven Shapiro | Marc S. Ullman | Intellectual Property | Compliance, Investigations & White Collar

Steven Shapiro and Marc Ullman wrote the article, “What Dietary Supplement Companies Can Do to Address Potential Counterfeiting of Their Products,” for the August 2023 issue of Nutrition Industry Executive.

The article explains how counterfeit products are going mainstream by moving to legitimate websites. It details how two dietary supplement companies determined that a fraudsters were

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Vitamin Retailer Publishes Ullman’s Article on Counterfeit Dietary Supplements
| Marc S. Ullman | Intellectual Property | Compliance, Investigations & White Collar

In its August 2023 issue, Vitamin Retailer published Marc Ullman’s article, “Counterfeiting Headaches Aren’t Just for High Fashion Retailers and Designers Anymore.”

The article explains how counterfeiters have entered the dietary supplements market and how their products have been able to proliferate. It also offers some advice on how consumers and retailers alike can protect themselves

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Modernization of Cosmetics Regulation Act of 2022
April 3, 2023 | Steven Shapiro | Compliance, Investigations & White Collar
FDA Will Have Extensive Authority to Regulate Cosmetics

Under the Federal Food, Drug and Cosmetic Act, 21 U.S.C. 321(i), “cosmetics” are defined as “articles intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body or any part thereof for cleansing, beautifying, promoting attractiveness or altering the appearance

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Ullman Interviewed about Potential FDA Lawsuits Over CBD
March 17, 2023 | Compliance, Investigations & White Collar
Marc Ullman was interviewed for Natural Products Insider’s article “Suing FDA over CBD would face procedural, substantive hurdles.“

The FDA is facing possible legal action after three citizen petitions were rejected by the administration. All petitions were requesting that the FDA allow for the inclusion of CBD in dietary supplements, through some trade groups.


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DOJ Issues New Guidance on Criminal Enforcement
February 22, 2023 | Geoffrey R. Kaiser | Compliance, Investigations & White Collar

Jeff Kaiser’s article, “DOJ Issues New Guidance on Criminal Enforcement,” appeared in the winter 2023 issue of USLAW Magazine.

Click here to read the article.

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Ullman Publishes Quarterly Column Analyzing The FDA’s Interpretation of the DSHEA Exclusionary Clause
January 6, 2023 | Health Services | Compliance, Investigations & White Collar

Marc Ullman was published in Natural Products Insider. His article, “Analysis: CBD food industry unlikely to placate FDA,” discusses the potentially negative impact on the FDA’s interpretation of the exclusionary clause in the Dietary Supplement Health and Education Act of 1994 (DSHEA). Ullman fears the current interpretation of the act will have a long lasting

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DOJ Issues New Guidance on Criminal Enforcement
October 10, 2022 | Geoffrey R. Kaiser | Corporate | Compliance, Investigations & White Collar

On September 15, Deputy Attorney General (“DAG”) Lisa Monaco delivered remarks announcing updated guidance on how the Department of Justice will be prioritizing and prosecuting corporate crime.  Her remarks were accompanied by a formal memo, titled “Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group” (  However inelegant the title,

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Treasury Issues Final Rule on Disclosure of Beneficial Ownership
September 29, 2022 | Katherine A. Heptig | Bernadette Kasnicki | Louis Vlahos | Tax | Compliance, Investigations & White Collar

In an effort to help prevent and combat money laundering, terrorist financing, corruption, tax fraud, and other illicit activity, the United States Department of the Treasury just issued a final rule [RIN: 1506-AB49]. The rule requires certain businesses to file reports with FinCEN (Financial Crimes Enforcement Network) that identify two categories of individuals: the beneficial

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Private Insurers Must Watch Out for Medical Equipment Fraud
August 10, 2022 | Michael Vanunu | Compliance, Investigations & White Collar | Insurance Fraud

Healthcare fraud related to durable medical equipment (DME) is extremely costly to insurers yet often continues without criminal or civil consequences.

Fraudulent schemes by DME supply companies vary in complexity but usually prove extremely costly to insurers. Likely victims of DME fraud include Medicaid, Medicare, automobile insurers, workers’ compensation insurers, and other private health insurers.

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