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DOJ Speaks with One Voice: What the New Department-Wide CEP Means for Corporate Self-Disclosure

On March 10, 2026, the U.S. Department of Justice (DOJ) published its “first-ever” Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (the “Department-wide CEP”), which will apply to all corporate...more

Government Scrutiny of Nonprofits Intensifies

Nonprofits continue to be closely scrutinized by the executive and legislative branches, as well as state attorneys general and legislatures, expressing interest in examining the ways in which foreign donors use nonprofits to...more

Top DOJ Official Shares Statistics Showing Surge in False Claims Act Trade Fraud Investigations

In remarks last week at the American Conference Institute’s Advanced Forum on False Claims and Qui Tam Enforcement, the Department of Justice’s (DOJ) top civil fraud enforcement official, Deputy Assistant Attorney General...more

PBM Reform Picks Up Pace with Enactment of Consolidated Appropriations Act, PBM Fee Disclosure Proposed Rule

Pharmacy benefit manager (PBM) reform has been an active and evolving area for policymakers in Washington, D.C. for many years but reform efforts have noticeably picked up pace in 2026. Recent actions by Congress and the...more

DOJ’s Year‑End Customs Fraud Enforcement Signals What’s Ahead in 2026

The U.S. Department of Justice (DOJ) closed out 2025 with a clear message to importers: the Trade Task Force is working hard and trade fraud enforcement will be accelerating into 2026. On one day, December 18, DOJ announced...more

White House Signals Escalated Fraud Enforcement

At a White House press briefing on Thursday, January 8, 2026, Vice President JD Vance outlined a nationwide fraud enforcement initiative anchored by a new Senate-confirmed Department of Justice (DOJ) leadership position that...more

DOJ Signals Coming Surge in Criminal Tariff-Evasion Enforcement

At the American Conference Institute’s 42nd Annual Conference on FCPA and Global Anti-Corruption held on December 4, 2025 in Washington, senior officials from the U.S. Department of Justice (DOJ) reaffirmed that combatting...more

DOJ and DHS Launch Cross-Agency Task Force to Combat Trade Fraud

On August 29, 2025, the U.S. Departments of Justice (DOJ) and Homeland Security (DHS) announced the creation of a new cross-agency Trade Fraud Task Force “to bring robust enforcement against importers and other parties who...more

Tariff Evasion and Customs Fraud Under the Microscope: DOJ Signals Aggressive Criminal Enforcement Ahead

Given the Trump Administration’s unprecedented reliance on tariffs as a foreign policy tool and a means to protect and foster U.S. industry, the U.S. Department of Justice (DOJ) is rapidly shifting resources and enforcement...more

DOJ Hits Play: The End of the FCPA “Pause” and Return to Enforcement

On June 9, 2025, the Deputy Attorney General issued a Memorandum detailing the administration’s new FCPA guidelines for all current and future investigations and enforcement actions. According to the Head of DOJ’s Criminal...more

DOJ’s Criminal Division Turns Page on White Collar Crime—But Keeps One Foot in the Past

On May 12, 2025, the DOJ announced a new “white-collar enforcement plan” identifying new corporate enforcement priorities and aiming to promote greater focus, fairness and efficiency in prosecuting corporate misconduct. In a...more

The European Response to DOJ’s FCPA Enforcement “Pause”

On March 20, 2025, the United Kingdom, France and Switzerland jointly announced the formation of a new International Anti-Corruption Prosecutorial Taskforce (the “Task Force”) aimed at strengthening cross-border collaboration...more

Red Notice Newsletter - October 2019

ANTICORRUPTION DEVELOPMENTS - Former Unaoil Executives Plead Guilty to FCPA Charges - On October 30, 2019, the Department of Justice (DOJ) announced that three former executives from Unaoil, a Monaco-based oil...more

Red Notice Newsletter - November 2018

ANTICORRUPTION DEVELOPMENTS - Deputy Attorney General Rod Rosenstein Announces Pursuing Individuals Will be a “Top Priority” for Corporate Enforcement Actions - On November 29, 2018, Deputy Attorney General Rod J....more

Red Notice Newsletter - August 2018

ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more

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