News & Analysis as of

Department of Justice (DOJ)

Brownstein Hyatt Farber Schreck

Regulators Finalize New Approach to Bank Mergers

On Sept. 17, 2024, the Federal Deposit Insurance Corporation (FDIC) Board met to finalize an updated approach to increase scrutiny of bank mergers, particularly those that would result in a bank with over $100 billion in...more

McDermott Will & Emery

DOJ Makes Key Revisions to Corporate Compliance Program Guidance

McDermott Will & Emery on

On September 23, 2024, the US Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs guidance (ECCP). Changes to the ECCP build on themes that the DOJ has been emphasizing for some time, including...more

Sheppard Mullin Richter & Hampton LLP

DOJ Announces Changes to Guidance on Corporate Compliance Programs, Updates on Whistleblower Program

In an address this week to the Society of Corporate Compliance and Ethics, Principal Deputy Assistant Attorney General Nicole M. Argentieri of the Department of Justice’s (“DOJ”) Criminal Division, highlighted several updates...more

Orrick, Herrington & Sutcliffe LLP

DOJ, HUD resolve redlining claims with New Jersey-based bank

On September 17, the DOJ and HUD announced a settlement with a New Jersey-based bank to resolve “redlining” lending discrimination allegations. The DOJ’s complaint claimed that from 2018 through at least 2022, the bank failed...more

Jenner & Block

Changes to Reporting Requirements for U.S. Defense Transactions

Jenner & Block on

The National Defense Authorization Act was revised in December to state that parties to an HSR-reportable transaction that “will require a review by the Department of Defense who are required to file the notification and...more

Fenwick & West LLP

DOJ ‘Upping the Ante’ for Corporate Self-Disclosure with New Corporate Whistleblower Awards Pilot Program

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Earlier in 2024, DOJ’s Criminal Division announced a new Corporate Whistleblower Awards Pilot Program granting whistleblower awards to individuals who provide information in four priority areas. ...more

Gardner Law

Hiring Conflicts Result in FCA Violations

Gardner Law on

A recent U.S. Department of Justice (DOJ) settlement highlights the importance of having (and following) a policy that prohibits conflicts of interest. In July 2024, the DOJ entered a nearly $1 million settlement with an...more

Foley & Lardner LLP

Research Misconduct: ORI Issues Final Rule with Modernized and Streamlined Regulations

Foley & Lardner LLP on

On September 17, 2024, the Office of Research Integrity (ORI) issued a final rule adopting changes to federal regulations governing research misconduct involving federally funded research (Final Rule). The regulations have...more

BakerHostetler

DOJ Withdraws 1995 Bank Merger Guidelines as FDIC, OCC Make Regulatory Changes

BakerHostetler on

On September 17, 2024, the Department of Justice Antitrust Division (DOJ) shut the vault doors on its 1995 Bank Merger Guidelines, leaving the 2023 Merger Guidelines as its sole authoritative statement on the topic of mergers...more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

Epstein Becker & Green

United States’ Complaint-in-Intervention Highlights Continuing Effort to Use the False Claims Act to Pursue Alleged Cybersecurity...

Epstein Becker & Green on

In August, the United States filed a Complaint-in-Intervention in a False Claims Act (FCA) whistleblower suit alleging that the Georgia Institute of Technology (“Georgia Tech”) and an affiliate, Georgia Tech Research Corp....more

Robinson+Cole Health Law Diagnosis

South Dakota Hospital Settles False Claims Act Allegations for Over $14 Million Following Self-Disclosure

On September 18, 2024, the Department of Justice (DOJ) announced a settlement with Dunes Surgical Hospital and United Surgical Partners International, Inc. (USPI), an entity holding a partial ownership interest in Dunes, in...more

Holland & Knight LLP

Federal Court Searches for Answers in Antitrust Ad Tech Trial Against Google

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Since early September 2024, the U.S. Department of Justice (DOJ) presented its case-in-chief against Google in a lawsuit accusing the company of anti-competitive and monopolistic practices in the complex digital advertising...more

Benesch

AI Reporter - September 2024

Benesch on

There has been a seismic shift in the relationship between Big Tech’s AI power couple, Microsoft and OpenAI. The former listed the AI pioneer as a competitor in its annual report, perhaps signaling a less friendly dynamic...more

McGuireWoods LLP

“Call Us Before We Call You”:  DOJ’s New Corporate Whistleblower Awards Pilot Program

McGuireWoods LLP on

On September 17, 2024, Deputy Assistant Attorney General Nicole Argentieri stressed the intense focus placed by the U.S. Department of Justice (DOJ or the Department) on incentivizing companies to maintain healthy corporate...more

Thomas Fox - Compliance Evangelist

Argentieri Speech and 2024 ECCP: Data Access and Data Analytics

Deputy Assistant Attorney General Nicole M. Argentieri’s speech highlighted a critical shift in the DOJ’s approach to evaluating corporate compliance programs. As outlined in the updated 2024 Evaluation of Corporate...more

Thomas Fox - Compliance Evangelist

Argentieri Speech: 6 Key Takeaways for the Compliance Programs

On Monday, Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. ( A copy of her remarks can be found here.) She...more

Wiley Rein LLP

Senators Look to Close Prominent FARA Registration Exemptions by Introducing STRATEGIC Act

Wiley Rein LLP on

On September 19, a group of Republican Senators led by Foreign Relations Committee Ranking Member Jim Risch (R-ID) introduced the STRATEGIC Act of 2024 to combat Chinese Communist Party (CCP) influence within the United...more

Guidepost Solutions LLC

Why Corporate Accountability for Criminal Behavior Makes Due Diligence More Crucial Than Ever

The U.K. Economic Crime and Corporate Transparency Act 2023 (“the Act”), passed in October 2023, strengthens the U.K. Government’s efforts to compel companies to weed out fraud, corruption, and other criminal activity. The...more

Thomas Fox - Compliance Evangelist

All Things Investigations: Anchored in Fraud: Mike DeBernardis and Shayda Vance on Austal USA’s Scandal

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox is joined by guests Mike DeBernardis and Shayda Vance to discuss the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Whistleblower Update: SEC, DOJ Still Focusing on Employment Agreements and Written Policies, Off-Channel Communications

The U.S. Securities and Exchange Commission (SEC) brought more actions targeting regulated entities for recordkeeping violations related to employees using noncompany communications platforms, and both the SEC and the U.S....more

ArentFox Schiff

investigations Newsletter: Walgreens Settles for $106.8 Million Over FCA Violations

ArentFox Schiff on

Walgreens Settles for $106.8 Million Over FCA Violations - On September 13, the US Department of Justice (DOJ) announced that Walgreens Boots Alliance Inc. and Walgreen Co. (collectively, Walgreens) agreed to pay $106.8...more

Hogan Lovells

It’s the final countdown... for self-disclosure under DOJ’s amended Corporate Enforcement Policy

Hogan Lovells on

The recent amendment to the Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) of the Department of Justice’s (DOJ’s) Criminal Division expects companies to self-disclose allegations of misconduct within 120...more

Pillsbury Winthrop Shaw Pittman LLP

Department of Justice Settles with Las Vegas Casino for $130 Million

The settlement is the latest example of the agency’s enhanced criminal enforcement of money transmitting business and international money-laundering laws. The recent settlement is significant both in terms of its amount...more

Orrick, Herrington & Sutcliffe LLP

DOJ announces its withdrawal from the 1995 Bank Merger Guidelines

On September 17, the DOJ announced its withdrawal from the 1995 Bank Merger Guidelines, stating the 2023 Merger Guidelines will be the only authoritative statement across all industries. This decision followed collaboration...more

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