Compliance, Investigations & White Collar
March 29, 2024 | Marc S. Ullman |
Marc S. Ullman, of counsel to Rivkin Radler, recently authored “FDA sends a message with two warning letters to Amazon” in Natural Products Insider.
In the article, Marc explains the importance of the FDA warning letters on homeopathic “supplements” and products that contain active pharmaceutical ingredients. Ullman writes, “During the last quarter of 2023,
Read MoreJanuary 30, 2024 | Jennifer F. Hillman | Wendy Hoey Sheinberg | | | |
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
Read MoreAugust 2, 2023 | Steven Shapiro | Marc S. Ullman | |
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
Read More| Marc S. Ullman | |
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
Read MoreApril 3, 2023 | Steven Shapiro |
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
Read MoreMarch 17, 2023 |
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.
Ullman
Read MoreFebruary 22, 2023 | Geoffrey R. Kaiser |
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.
Read MoreJanuary 6, 2023 | |
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
Read MoreOctober 10, 2022 | Geoffrey R. Kaiser | |
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” (https://www.justice.gov/opa/speech/file/1535301/download). However inelegant the title,
Read MoreSeptember 29, 2022 | Katherine A. Heptig | Bernadette Kasnicki | Louis Vlahos | |
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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