
Publication
Navigating international trade and tariffs
Impacts of evolving trade regulations and compliance risks
Publication | August 11, 2015
In the first decision interpreting the 60-day overpayment rule of the False Claims Act, U.S. District Judge Edgardo Ramos of the Southern District of New York held that an overpayment has been "identified" for the purposes of starting the 60-day overpayment refund clock when "a provider has been put on notice of a potential overpayment, rather than the moment when an overpayment is conclusively ascertained[.]" While this is likely to be one of many decisions on the subject, this decision suggests that providers may face potentially significant risk for failure to promptly identify and return overpayments going forward.
The 60-day overpayment rule was created by Section 6402(d) of the Affordable Care Act.
Read the full article: Risks arise for health providers after FCA overpayment case
Publication
Impacts of evolving trade regulations and compliance risks
Publication
As the UK’s Office of Financial Sanctions Implementation (OFSI) proposes reforms to its civil enforcement processes for financial sanctions and geopolitical developments impacting sanctions regimes continue at pace, sanctions remain a key area of focus not only for UK regulators in the context of enforcement, but also in a number of cases before the English Courts.
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The ocean is the world’s life support system and our greatest ally in our defence against climate change impacts. As eloquently described at the 2022 United Nations Ocean Conference.
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