Former Georgia Supervisory Correctional Officer Pleads Guilty to Civil Rights Offenses for Assaulting Inmates

A former supervisory correctional officer at the Valdosta State Prison (VSP) in Valdosta, Georgia, pleaded guilty today to violating the civil rights of two inmates during two separate incidents.

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    In U.S GAO News
    The 340B Drug Pricing Program (340B Program) requires drug manufacturers to sell outpatient drugs at a discount to covered entities—eligible hospitals and other entities participating in the program—in order for their drugs to be covered by Medicaid. Participation in the 340B Program has grown from nearly 9,700 covered entities in 2010 to 12,700 in 2020. The Department of Health and Human Services' (HHS) Health Resources and Services Administration (HRSA) administers the program and oversees covered entities' compliance with 340B Program requirements through annual audits, among other efforts. If audits identify noncompliance with program requirements, HRSA issues findings to covered entities and requires them to take corrective action to continue participating in the 340B Program (see table). Audit Findings Issued to Covered Entities by the Health Resources and Services Administration (HRSA) for Fiscal Years 2012-2019, as of September 2020 340B Program findings of noncompliance Number Eligibility of covered entities. Failure to maintain eligibility-related requirements (e.g., covered entities' oversight of their contract pharmacies). 561 Diversion of 340B drugs to ineligible patients. 340B drugs distributed to individuals who are not eligible patients of a covered entity (e.g., patients' health records are not maintained by the covered entity). 546 Duplicate discounts. Prescribed drugs that may have been subject to both the 340B price and a Medicaid rebate. 429 Total 1,536 Source: GAO analysis of information received from HRSA. | GAO-21-107 HRSA officials told GAO that, beginning in fall 2019, the agency started issuing findings only when audit information presents a clear and direct violation of the requirements outlined in the 340B Program statute. HRSA officials explained that guidance, which is used to interpret provisions of the 340B statute for the purposes of promoting program compliance among covered entities, does not provide the agency with appropriate enforcement capability. For example, HRSA officials reported that there were instances among fiscal year 2019 audits in which the agency did not issue findings for a failure to comply with guidance related to contract pharmacies in part because the 340B statute does not address contract pharmacy use and, therefore, there may not have been a clear statutory violation. In addition to audits, HRSA provides education to covered entities about 340B Program requirements and has implemented other efforts to identify noncompliance. For example, HRSA requires all covered entities to recertify their eligibility to participate in the 340B Program annually (e.g., self-attesting to compliance); and uses a self-disclosure process through which covered entities can disclose and correct self-identified instances of noncompliance. Covered entities can realize substantial savings through 340B Program price discounts, enabling them to stretch federal resources to reach more eligible patients and provide more comprehensive services. GAO was asked to provide information on HRSA's efforts to oversee covered entities' compliance with 340B Program requirements. This report describes (1) the audit findings that HRSA issued to address covered entity noncompliance with 340B Program requirements; and (2) other efforts HRSA uses to help ensure that covered entities comply with 340B Program requirements. GAO reviewed documentation, including relevant federal laws and regulations and HRSA's policies, procedures, and guidance, related to 340B Program oversight. GAO also reviewed HRSA data on the number and type of audit findings made from audits finalized during fiscal years 2012 through 2019 as of September 2020—the latest data available at the time of the audit. GAO also interviewed officials from HRSA, agency contractors, and 340B Program stakeholders. GAO provided a draft of this report to HHS for review. The agency provided written and technical comments on the draft, both of which were incorporated as appropriate. For more information, contact Debra A. Draper at (202) 512-7114 or draperd@gao.gov.
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    In U.S GAO News
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Estimated Frequency with Which Criminal Investigators Who Reported Using BSA Reports Almost Always, Frequently, or Occasionally Found Relevant Reports for Various Activities, 2015–2018 Notes: GAO conducted a generalizable survey of 5,257 personnel responsible for investigations, analysis, and prosecutions at the Drug Enforcement Administration, Federal Bureau of Investigation, Homeland Security Investigations, Internal Revenue Service-Criminal Investigation, Offices of U.S. Attorneys, and U.S. Secret Service. The margin of error for all estimates is 3 percentage points or less at the 95 percent confidence interval. As of December 2018, GAO found that the Financial Crimes Enforcement Network (FinCEN) granted the majority of federal and state law enforcement agencies and some local agencies direct access to its BSA database, allowing them to conduct searches to find relevant BSA reports. FinCEN data show that these agencies searched the BSA database for about 133,000 cases in 2018—a 31 percent increase from 2014. FinCEN created procedures to allow law enforcement agencies without direct access to request BSA database searches. But, GAO estimated that relatively few local law enforcement agencies requested such searches in 2018, even though many are responsible for investigating financial crimes. GAO found that agencies without direct access may not know about BSA reports or may face other hurdles that limit their use of BSA reports. One of FinCEN's goals is for law enforcement to use BSA reports to the greatest extent possible. However, FinCEN lacks written policies and procedures for assessing which agencies without direct access could benefit from greater use of BSA reports, reaching out to such agencies, and distributing educational materials about BSA reports. By developing such policies and procedures, FinCEN would help ensure law enforcement agencies are using BSA reports to the greatest extent possible to combat money laundering and other crimes. GAO reviewed a nongeneralizable sample of 11 banks that varied in terms of their total assets and other factors, and estimated that their total direct costs for complying with the BSA ranged from about $14,000 to about $21 million in 2018. Under the BSA, banks are required to establish BSA/anti-money laundering compliance programs, file various reports, and keep certain records of transactions. GAO found that total direct BSA compliance costs generally tended to be proportionally greater for smaller banks than for larger banks. For example, such costs comprised about 2 percent of the operating expenses for each of the three smallest banks in 2018 but less than 1 percent for each of the three largest banks in GAO's review (see figure). At the same time, costs can differ between similarly sized banks (e.g., large credit union A and B), because of differences in their compliance processes, customer bases, and other factors. In addition, requirements to verify a customer's identity and report suspicious and other activity generally were the most costly areas—accounting for 29 and 28 percent, respectively, of total compliance costs, on average, for the 11 selected banks. Estimated Total Direct Costs for Complying with the Bank Secrecy Act as a Percentage of Operating Expenses and Estimated Total Direct Compliance Costs for Selected Banks in 2018 Notes: Estimated total direct compliance costs are in parentheses for each bank. Very large banks had $50 billion or more in assets. Small community banks had total of assets of $250 million or less and met the Federal Deposit Insurance Corporation's community bank definition. Small credit unions had total assets of $50 million or less. Federal banking agencies routinely examine banks for BSA compliance. FinCEN data indicate that the agencies collectively cited about 23 percent of their supervised banks for BSA violations each year in their fiscal year 2015–2018 examinations. A small percentage of these violations involved weaknesses in a bank's BSA/anti-money laundering compliance program, which could require the agencies by statute to issue a formal enforcement action. Stakeholders had mixed views on industry proposals to increase the BSA's dollar thresholds for filing currency transaction reports (CTR) and suspicious activity reports (SAR). For example, banks must generally file a CTR when a customer deposits more than $10,000 in cash and a SAR if they identify a suspicious transaction involving $5,000 or more. If both thresholds were doubled, the changes would have resulted in banks filing 65 percent and 21 percent fewer CTRs and SARs, respectively, in 2018, according to FinCEN analysis. Law enforcement agencies told GAO that they generally are concerned that the reduction would provide them with less financial intelligence and, in turn, harm their investigations. In contrast, some industry associations told GAO that they support the changes to help reduce BSA compliance costs for banks. Money laundering and terrorist financing pose threats to national security and the U.S. financial system's integrity. The BSA requires financial institutions to file suspicious activity and other reports to help law enforcement investigate these and other crimes. FinCEN administers the BSA and maintains BSA reports in an electronic database that can be searched to identify relevant reports. Some banks cite the BSA as one of their most significant compliance costs and question whether BSA costs outweigh its benefits in light of limited public information about law enforcement's use of BSA reports. GAO was asked to review the BSA's implementation. This report examines (1) the extent to which law enforcement uses BSA reports and FinCEN facilitates their use, (2) selected banks' BSA compliance costs, (3) oversight of banks' BSA compliance, and (4) stakeholder views of proposed changes to the BSA. GAO surveyed personnel at six federal law enforcement agencies, collected data on BSA compliance costs from 11 banks, reviewed FinCEN data on banking agencies' BSA examinations, and interviewed law enforcement and industry stakeholders on the effects of proposed changes. GAO is recommending that FinCEN develop written policies and procedures to promote greater use of BSA reports by law enforcement agencies without direct database access. FinCEN concurred with GAO's recommendation. For more information, contact Michael Clements at (202) 512-8678 or clementsm@gao.gov.
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    In U.S GAO News
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    In Crime News
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    In Crime News
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    In U.S GAO News
    While the military services—Army, Navy, Marine Corps, and Air Force—provide an annual clothing allowance to replace uniform items initially issued to enlisted service members, GAO found that some items are excluded from the allowance. This can result in out-of-pocket costs for both female and male enlisted service members. Moreover, DOD's uniform allowance policy does not provide the services with consistent criteria for designating which items are considered uniquely military and included in the allowance, and which items are not and are excluded from the allowance. For example, the Air Force and Marine Corps provide an allowance for an all-weather coat, but the Army does not. We found these differences in replacement allowances can also contribute to differences in out-of-pocket costs by service and gender for enlisted service members (see figure). Developing consistent criteria for uniquely military items and periodically reviewing uniform replacement allowances could strengthen DOD's ability to identify and address any out-of-pocket cost differences across the services as well as between female and male enlisted service members. Number and Total Value of Fiscal Year 2020 Enlisted Service Member Clothing Items Included in the Initial Clothing Issue but Excluded from the Services' Calculations for Standard Cash Clothing Replacement Allowances, by Service and Gender The military services made numerous uniform changes over the past 10 years and the changed uniform items were generally more expensive. GAO found that Navy and Marine Corps female enlisted service members and officers were most affected by uniform changes. In addition, GAO found that uniform changes could result in higher costs for officers who generally pay out-of-pocket for uniform costs. While the services have the authority to determine what uniforms are required for enlisted service members and officers, uniform changes have the potential to drive out-of-pocket costs for both. With equity as an underlying principle for compensation, a review of the services' uniform changes and resulting costs could help minimize out-of-pocket cost differences across the department and between genders. The total value of military uniform items for a newly enlisted service member ranges from about $1,600 to $2,400, depending on the military service. Over the course of their careers, service members must replace and maintain their uniforms. The conference report accompanying the National Defense Authorization Act for Fiscal Year 2020 included a provision for GAO to study service members' out-of-pocket costs for uniforms. Among other objectives, this report 1) assesses the extent to which differences exist in out-of-pocket costs for enlisted service member uniforms, by military service and by gender; and 2) examines the extent to which the military services have changed uniforms over the past 10 years, and how the costs of these changes have varied by service, enlisted or officer status, and gender. GAO reviewed DOD policies and service data on uniform allowances, enlisted and officer required uniform items and their costs, and changes made to uniforms since 2010. GAO also interviewed relevant DOD officials and service organization representatives. GAO is making four recommendations to improve DOD's understanding of out-of-pocket costs and to address any cost differences, including that it develop consistent criteria for excluding items from replacement allowances and review planned uniform changes. DOD concurred with all four recommendations. For more information, contact Tina Won Sherman at (202) 512-8461 or shermant@gao.gov.
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    In Crime News
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  • Aircraft Noise: Information on a Potential Mandated Transition to Quieter Airplanes
    In U.S GAO News
    Based on Federal Aviation Administration (FAA) data and GAO estimates, most U.S. large commercial jet airplanes are certificated at the minimum required stage 3 noise standards, but nearly all of them are able to meet more stringent noise standards. Sixty-three percent of large commercial airplanes in the United States are certificated as meeting the stage 3 standards; however, 87 percent of them were manufactured with technologies that are able to meet more recent and stringent stage 4 or 5 standards as currently configured, according to FAA's 2017 analysis. By analyzing updated data from airlines and aviation manufacturers, GAO estimated that this proportion is even higher: 96 percent of large commercial airplanes are able to meet stage 4 or 5 standards (see figure). According to FAA officials and aviation stakeholders, the primary reason many large commercial airplanes certificated as stage 3 produce lower than stage 3 noise levels is because engine and airframe technology has outpaced the implementation of noise standards. More recently, some airlines have accelerated retirement of certain airplanes, some of which are certificated as stage 3, due to the decrease in travel amid the COVID-19 pandemic. For the generally smaller regional commercial jets (i.e., generally with less than 90 seats), 86 percent are able to meet stage 4 or stage 5 standards, according to manufacturers' data. With regard to general aviation (which are used for personal or corporate flights), 73 percent of the jet airplanes in that fleet are able to meet the more stringent stage 4 or 5 standards, according to manufacturers' data. GAO Estimate of The Number of Large Airplanes in the U.S. Commercial Fleet That Are Able to Meet Stage 3 or Stage 4 and 5 Noise Standards, January 2020 According to stakeholders GAO interviewed, a phase-out of jet airplanes that are certificated as meeting stage 3 standards would provide limited noise reduction and limited other benefits, and could be costly and present other challenges. A phase-out could require recertificating the vast majority of stage 3 airplanes to comply with stage 4 or 5 standards. This process could be costly for operators and manufacturers but would provide little reduction in noise. Further, airplanes currently unable to meet more stringent standards would require modifications or face retirement. For older airplanes that could not be recertificated to meet stage 4 or 5 standards, some operators could incur costs for replacement airplanes sooner than originally planned. Although stakeholders indicated that a phase-out would not substantially reduce noise, they identified other limited benefits newer airplanes generate, such as reduced greenhouse gas emissions and fuel consumption. Although advances in technology have led to quieter aircraft capable of meeting increasingly stringent noise standards, airport noise remains a concern. FAA regulates aircraft noise by ensuring compliance with relevant noise standards. In 1990, federal law required large jet airplanes to comply with stage 3 noise standards by 1999, leading to a phase-out of the noisiest airplanes (stage 1 and 2 airplanes). Later, federal law required smaller airplanes to comply with stage 3 standards by 2016. The FAA Reauthorization Act of 2018 included a provision for GAO to review a potential phase-out of stage 3 airplanes—the loudest aircraft currently operating in the United States. This report describes (1) the proportion of stage 3 airplanes in the U.S. fleet, and what proportion of these stage 3 airplanes are able to meet more stringent noise standards and (2) selected stakeholders' views on the potential benefits, costs, and challenges of phasing out stage 3 airplanes. GAO reviewed FAA's analysis of December 2017 fleet data, analyzed January 2020 fleet data from select airlines and airframe and engine manufacturers, and interviewed FAA officials. GAO also interviewed a non-generalizable sample of 35 stakeholders, including airlines; airframe and engine manufacturers; airports; and industry associations, selected based on fleet and noise data, stakeholder recommendations, or prior GAO knowledge. For more information, contact Heather Krause at (202) 512-2834 or krauseh@gao.gov.
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    In Crime News
    Today, Attorney General William Barr, Director of the FBI, Christopher Wray, Assistant Attorney General for National Security John Demers, and Acting U.S. Attorney for the District of Columbia, Michael Sherwin, announced new charges against a former Libyan intelligence operative, Abu Agela Mas’ud Kheir Al-Marimi, aka, “Hasan Abu Ojalya Ibrahim” (Masud), for his role in building the bomb that killed 270 individuals in the destruction of Pan Am Flight 103 over Lockerbie, Scotland on Dec. 21, 1988.
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    A recent program honoring the 25th anniversary of a landmark case allowing women to enroll in the Virginia Military Institute (VMI) also celebrated a broader theme: Justice Ruth Bader Ginsburg’s decades-long effort to remove gender bias from state and federal laws.
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  • Medicaid: HHS’s Preliminary Analyses Offer Incomplete Picture of Behavioral Health Demonstration’s Effectiveness
    In U.S GAO News
    What GAO Found The Protecting Access to Medicare Act of 2014 (PAMA) established the Certified Community Behavioral Health Clinics (CCBHC) demonstration and tasked the Department of Health and Human Services (HHS) with its implementation. CCBHCs aim to improve the behavioral health services they provide, particularly for Medicaid beneficiaries. Initially established for a 2-year period, the demonstration has been extended by law a number of times; most recently, it was extended to September 2023. States participating in the demonstration can receive Medicaid payments, consistent with federal requirements, for CCBHC services provided to beneficiaries. PAMA also required HHS to assess the effect of the demonstration on service access, costs, and quality. HHS's preliminary assessments of the demonstration in eight states, with 66 participating CCBHCs, found the following: Access. CCBHCs commonly added services related to mental and behavioral health, such as medication-assisted treatment, and took actions to provide services outside the clinic setting, such as through telehealth. Costs. States' average payments to CCBHCs typically exceeded CCBHC costs for the first 2 years of the demonstration. CCBHC payments and costs were more closely aligned in the second year for most states, better reflecting the payment methods prescribed under the demonstration. Quality. States and CCBHCs took steps, such as implementing electronic health records systems, to report performance on 21 quality measures. GAO found data limitations complicated—and will continue to affect—HHS's efforts to assess the effectiveness of the demonstration. For example: Lack of baseline data. PAMA requires HHS to assess the quality of services provided by CCBHCs compared with non-participating areas or states. The demonstration marked the first time these clinics reported performance on quality measures, so no historical baseline data exist. HHS officials noted that with time, additional data may provide insight on the quality of services. Lack of comparison groups. PAMA requires HHS to compare CCBHCs' efforts to increase access and improve quality with non-participating clinics and states. HHS was unable to identify comparable clinics or states due to significant differences among the communities. Lack of detail on Medicaid encounters. PAMA requires HHS to assess the effect of the demonstration on federal and state costs and on Medicaid beneficiaries' access to services. HHS plans to use Medicaid claims and encounter data to assess such changes. However, GAO has previously identified concerns with the accuracy and completeness of Medicaid data and has made numerous recommendations aimed at improving their quality. HHS's decisions in implementing the demonstration also complicated its assessment efforts. HHS allowed states to identify different program goals and target populations, and to cover different services. HHS also did not require states to use standard billing codes and billing code modifiers it developed. The lack of standardization across states limited HHS's ability to assess changes in a uniform way. Why GAO Did This Study Behavioral health conditions—mental health issues and substance use disorders—affect millions of people. HHS estimates that 61 million adults had at least one behavioral health condition in 2019—41 million of whom did not receive any related treatment in the prior year. Many individuals with behavioral health conditions rely on community mental health centers for treatment, but the scope and quality of these services vary. To improve community-based behavioral health services, PAMA created the CCBHC demonstration and provided HHS with $25 million to support its implementation. PAMA directed HHS to assess the demonstration and to provide recommendations for its continuation, modification, or termination. To date, HHS has issued three annual reports assessing the initial demonstration period, which ran from 2017 to 2019. HHS plans to issue a fourth annual report and a final report by December 2021. This report describes HHS's assessment of the demonstration regarding access, costs, and quality. Under the CARES Act, GAO is to issue another report on states' experiences by September 2021. GAO reviewed federal laws and regulations; HHS guidance; and HHS's assessments of the demonstration, including three issued reports, interim reports, and the analysis plan for future reports. GAO also interviewed HHS officials and officials from organizations familiar with community health clinics. HHS provided technical comments, which GAO incorporated as appropriate. For more information, contact Carolyn L. Yocom (202) 512-7114 or yocomc@gao.gov.
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  • Justice Department Settles with New York-Based Pharmaceutical Manufacturing Company to Resolve Immigration-Related Discrimination Claims
    In Crime News
    The Department of Justice announced yesterday that it reached a settlement with LNK International Inc. (LNK), a Hauppauge, New York-based manufacturer of over-the-counter pharmaceuticals. The settlement resolves the department’s claims that LNK violated the Immigration and Nationality Act (INA) when it discriminated against work-authorized non-U.S. citizens.  
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    Two members of the Aryan Circle (AC) pleaded guilty this week to their roles in a violent assault of a man in October 2016.
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    In Crime News
    A Montana chiropractor and his wife pleaded guilty today to tax evasion, announced Principal Deputy Assistant Attorney General Richard E. Zuckerman of the Department of Justice’s Tax Division and U.S. Attorney Kurt G. Alme for the District of Montana.
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  • Countering Violent Extremism: DHS Needs to Improve Grants Management and Data Collection
    In U.S GAO News
    While the Department of Homeland Security (DHS) followed the Office of Management and Budget (OMB) guidance for announcing the 2016 Countering Violent Extremism (CVE) Grant Program and reviewing applications, DHS did not document the basis for its final award decisions. In June 2017, DHS awarded a total of $10 million in CVE grants to 26 grantees for a 2-year performance period (2017 to 2019). Consistent with OMB guidance, DHS included program priorities and eligibility requirements in its grant announcement and described the process for reviewing and selecting grant applications for award. However, after DHS announced its selection of 31 applications for awards, it ran a new process resulting in revised selections, which was based on additional selection criteria not expressly listed in the grant announcement. While DHS officials explained to GAO how these additional criteria aligned with the grant announcement, these explanations do not appear in DHS's award documentation. Without such documentation, DHS cannot clearly demonstrate that its award decisions were based on the process described in the grant announcement. Figure: Location and Number of Deaths Associated with Domestic Extremist Attacks, 2010-2019 DHS did not obtain the necessary data from grantees to evaluate the overall CVE grant program. DHS required grant organizations to develop, collect, and submit their own output and outcome-related information to help enable the department to evaluate individual grantees and the overall grant program. However, a DHS review of four grant projects concluded that the grantees did not collect the type of performance information DHS needed to determine the grants' effectiveness, such as data at various time intervals to assess change in attitudinal behavior. Taking steps to ensure grantees collect and submit appropriate performance data would enable DHS to evaluate the extent that individual grant projects and the overall grant program are achieving results. Such information would help DHS manage the program and make adjustments as warranted. From 2010 through 2019, data collected through the Extremist Crime Database show that 205 deaths resulted from 59 violent extremist attacks in the United States. DHS received funding in 2016 to establish a new CVE Grant Program to support efforts by state and local governments and nongovernmental organizations to reduce risk factors associated with violent extremism. GAO was asked to review management of the CVE Grant Program. This report examines, among other things, the extent to which DHS (1) announced, reviewed, and awarded CVE grants in accordance with OMB guidance and (2) evaluated the performance of CVE grantees and the overall program. GAO reviewed documentation of DHS's actions in announcing, reviewing and awarding CVE grants; and documentation on steps taken to assess the performance of grantees and the overall program; as compared to requirements in key documents, including the CVE grant announcement, elements of internal control, and a DHS 2017 report to Congress. GAO recommends that DHS, for future CVE-related grant programs: (1) develop policy to document the rationale for award decisions, and (2) take steps to ensure that grantees collect and submit data on project performance that enable evaluation of individual grants and the overall grant program toward intended outcomes. DHS concurred with both recommendations. For more information, contact Triana McNeil at (202) 512-8777 or mcneilt@gao.gov.
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    In Crime News
    The Department of Justice announced today that it is requiring Liberty Latin America Ltd. (Liberty), its subsidiary, Liberty Communications of Puerto Rico LLC (LCPR), and AT&T Inc. (AT&T) to divest certain fiber-based telecommunications assets and customer accounts in Puerto Rico, in order for Liberty to proceed with its proposed acquisition of AT&T’s wireline and wireless telecommunications operations in Puerto Rico and the U.S. Virgin Islands.  The department has approved WorldNet Telecommunications, Inc. (WorldNet) as the acquirer. 
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    In Crime News
    The Department of Justice announced today that it will require Zen-Noh Grain Corp. (ZGC) to divest nine grain elevators in nine geographic areas located in five states along the Mississippi River and its tributaries in order to proceed with its proposed $300 million acquisition of 35 operating and 13 idled grain elevators from Bunge North America Inc. 
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    The Justice Department today marked the 20th Anniversary of the Religious Land Use and Institutionalized Persons Act (RLUIPA) by releasing a comprehensive report detailing how RLUIPA has helped preserve the religious liberty rights of thousands of individuals and institutions. 
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    Federal judges are working to make highly sought-after law clerkships and judicial internships more accessible to a diverse pool of law students.
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  • Jacksonville Woman Pleads Guilty to Attempting to Illegally Exporting Maritime Raiding Craft and Engines to China
    In Crime News
    Yang Yang (34, Jacksonville) has pleaded guilty to conspiring to submit false export information through the federal government’s Automated Export System and to fraudulently export to China maritime raiding craft and engines in violation of United States (U.S.) law, and also to attempting to fraudulently export that equipment in violation of U.S. law. Yang faces a maximum penalty of 15 years in federal prison. A sentencing date has not yet been set.
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  • Georgia CPA Indicted for Promoting Syndicated Conservation Easement Tax Scheme Involving Fraudulent Charitable Deductions
    In Crime News
    A federal grand jury sitting in Atlanta, Georgia, returned an indictment today charging an Atlanta certified public accountant with one count of conspiracy to defraud the United States; 24 counts of wire fraud; 32 counts of aiding or assisting in the preparation of false federal tax returns; and five counts of filing false federal tax returns relating to a wide-ranging, abusive tax shelter scheme. 
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