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Health Care Cos. Ought To Note Joint AKS, FCPA Action, O’Melveny Lawyers Write

April 04, 2016

O’Melveny partners David Kirman and Jeremy Maltby and associate Alex Wyman co-authored the March 31, 2016, Daily Journal article, "Companies Should Note Joint AKS, FCPA Action." According to the authors, health care companies should take steps to safeguard against the considerable risk of liability presented by joint enforcement under the AKS and FCPA. “Essential steps include educating employees about the risks that these statutes present, instituting an effective compliance program tailored to the specific needs of the company, and allocating responsibility for compliance mechanisms and rules,” the authors conclude in the article.

Kirman is a trial lawyer based in O’Melveny’s Century City office who draws on his experience as a former federal prosecutor to represent clients in government investigations, prosecutions, and business disputes. Maltby, a former special assistant and senior counsel to President Obama, resides in O’Melveny’s Washington, DC and assists clients with complex issues in the areas of constitutional, regulatory, criminal, and international law. Wyman is based in O’Melveny’s Los Angeles office and is a member of O’Melveny’s White Collar Defense and Corporate Investigations Practice.