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Illinois Asks for Permission to Import Drugs
Illinois governor Rod R. Blagojevich sent a letter on December 22 to Secretary of Health and Human Services Tommy Thompson asking that Thompson approve Illinois' plan to import pharmaceutical products from Canada for use by the state's employees and retirees. The governor, who has been pushing for months to gain the right to purchase drugs for Illinois from less-expensive sources in Canada, stated in his letter, “I was encouraged by your recent statements regarding your willingness to approve a small-scale demonstration project around the issue of re-importation of prescription drugs from Canada. We would like to work with you to design an effective pilot program that complies with the law.” Blagojevich hopes his state will become the “small-scale demonstration project” Thompson spoke of.
The Governor's Plan
The DOJ's Corporate Enforcement Policy: One Year Later
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
The DOJ's New Parameters for Evaluating Corporate Compliance Programs
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
Use of Deferred Prosecution Agreements In White Collar Investigations
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
Bankruptcy Sales: Finding a Diamond In the Rough
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.
Compliance Officers: Recent Regulatory Guidance and Enforcement Actions and Mitigating the Risk of Personal Liability
This article explores legal developments over the past year that may impact compliance officer personal liability.