On February 24, the US Securities and Exchange Commission’s (SEC) Division of Enforcement published a revised Enforcement Manual, replacing the version that had been in effect since November 2017....more
A coalition of US Senate Democrats introduced the FCPA Reinforcement Act, legislation aimed at strengthening enforcement of the Foreign Corrupt Practices Act (FCPA) amid concerns that the Trump Administration has weakened...more
On February 6, bipartisan members of the US Helsinki Commission, led by Chairman Senator Roger Wicker, called on US Attorney General Pam Bondi, US Secretary of the Treasury Scott Bessent, and US Secretary of Commerce Howard...more
On January 22, 2026, the US Department of Justice (DOJ) Criminal Division’s Fraud Section released its 2025 Year in Review (the Report), detailing its enforcement efforts and priorities....more
2/12/2026
/ Corporate Misconduct ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Healthcare Fraud ,
Indictments ,
Non-Prosecution Agreements ,
Popular ,
White Collar Crimes
For the first time in 15 years, the World Bank Group (WBG) has updated their Integrity Compliance Guidelines....more
On September 25, President Trump directed federal agencies to investigate and prosecute organizations and individuals that engage in “acts of political violence.”...more
The US Department of Justice (DOJ) declined to prosecute Liberty Mutual after the insurer voluntarily self-disclosed misconduct....more
On July 8, the US Department of Justice’s (DOJ) Antitrust Division, in partnership with the United States Postal Service (USPS), announced the launch of a Whistleblower Rewards Program. This new initiative is designed to...more
On June 9, Deputy US Attorney General Todd Blanche issued a memorandum outlining new guidelines for the enforcement of the Foreign Corrupt Practices Act (FCPA)....more
The US Department of Justice (DOJ) revised its Criminal Division Corporate Enforcement and Voluntary Disclosure Policy (CEP), outlining the benefits a company may earn by voluntarily self-disclosing misconduct, as well as the...more
On May 12, Matthew R. Galeotti, the head of the US Department of Justice’s (DOJ) Criminal Division, announced a new white collar enforcement plan, outlined changes to the Corporate Enforcement and Voluntary Disclosure Policy,...more
On April 2, California Attorney General (AG) Rob Bonta issued an alert reminding businesses operating in California that it is illegal to violate the Foreign Corrupt Practices Act (FCPA)....more
4/10/2025
/ Anti-Corruption ,
Bribery ,
California ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Requirements ,
State Attorneys General ,
Unfair Competition Law (UCL)
Last week, Attorney General Pamela Bondi issued 14 memoranda outlining new enforcement priorities at the US Department of Justice (DOJ). Notably, DOJ resources will shift away from the Foreign Corrupt Practices Act (FCPA) and...more
2/11/2025
/ Anti-Corruption ,
Attorney General ,
Corporate Governance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Agents Registration Act (FARA) ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Regulatory Requirements ,
White Collar Crimes
This past September, the US Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs (ECCP). The revised guidance reflects the government’s evolving expectations regarding corporate responsibility...more
11/18/2024
/ Anti-Retaliation Provisions ,
Artificial Intelligence ,
Code of Conduct ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Employee Training ,
Incentives ,
NIST ,
Risk Management ,
Technology ,
Whistleblower Hotlines ,
Whistleblowers
In December 2023, US Congress passed a landmark anti-bribery law: the Foreign Extortion Prevention Act (FEPA). FEPA was designed to supplement the Foreign Corrupt Practices Act (FCPA) and expand liability to foreign...more
Numerous regulatory jurisdictions internationally, as well as multiple nongovernmental organizations (NGOs) such as the World Bank, have increasingly used compulsory corporate monitorships as part of their respective...more
On March 7, at the annual American Bar Association (ABA) National Institute on White Collar Crime, US Deputy Attorney General (DAG) Lisa Monaco announced a new whistleblower program that will provide financial rewards to...more
3/19/2024
/ Attorney General ,
CFTC ,
Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Pilot Programs ,
Regulatory Agenda ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more
1/15/2024
/ Bribery ,
Clawbacks ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Due Diligence ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Instant Messaging Apps ,
Policies and Procedures ,
Political Contributions ,
Remediation ,
Risk Assessment ,
SAP SE ,
Securities and Exchange Commission (SEC) ,
Settlement
On December 21 President Biden signed the Foreign Extortion Prevention Act (FEPA) as part of the Fiscal Year 2024 National Defense Authorization Act. The legislation addresses a perceived gap in the Foreign Corrupt Practices...more
12/28/2023
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Due Diligence ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
NDAA ,
Policies and Procedures ,
Risk Assessment ,
Securities and Exchange Commission (SEC)
Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance. In the past few months, the DOJ has entered into settlement agreements that...more
11/15/2023
/ Anti-Corruption ,
Clawbacks ,
Compensation ,
Compliance ,
Corporate Misconduct ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
Self-Disclosure Requirements ,
Settlement
On October 4, Deputy Attorney General Lisa O. Monaco addressed the Society of Corporate Compliance and Ethics and announced a new Department-wide Mergers & Acquisition (M&A) Safe Harbor policy. According to the new policy,...more
10/17/2023
/ Acquisitions ,
Anti-Corruption ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Due Diligence ,
Foreign Corrupt Practices Act (FCPA) ,
Mergers ,
Safe Harbors ,
Self-Disclosure Requirements
Amec Foster Wheeler Energy Limited (the Company), a subsidiary of John Wood Group plc (Wood), a United Kingdom-based global engineering company, agreed to pay more than $41 million in penalties and disgorgement for alleged...more
7/1/2021
/ Consent Order ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Intermediaries ,
Penalties ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Third-Party Risk
On May 21, 2021, SavaSeniorCare LLC and several of its affiliates, which own and operate skilled nursing facilities across the country, agreed to pay $11.2 million to resolve claims that the companies billed Medicare for...more
6/1/2021
/ Coronavirus/COVID-19 ,
Corporate Integrity Agreement ,
Defense Production Act ,
Department of Defense (DOD) ,
Department of Health and Human Services (HHS) ,
False Claims Act (FCA) ,
Medicaid ,
Medical Reimbursement Plans ,
Medicare ,
OIG ,
Provider Relief Fund ,
Securities and Exchange Commission (SEC) ,
Skilled Nursing Facility ,
USPTO
Where’s the Beef? Two Charged with $650 Million Cattle Ponzi Scheme -
On May 12, the Department of Justice (DOJ) announced that a federal district court in Colorado unsealed an indictment alleging that two individuals ran...more
5/17/2021
/ Centers for Medicare & Medicaid Services (CMS) ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Financial Markets ,
Healthcare Fraud ,
Investment Fraud ,
Investment Funds ,
Mergers ,
Misrepresentation ,
Pharmaceutical Industry ,
Ponzi Scheme ,
Public Comment ,
Securities and Exchange Commission (SEC) ,
State and Local Government ,
Stock Prices
Pharmaceutical Company Agrees to Pay $12.6 Million to Settle FCA Allegations Involving Kickbacks -
On Tuesday, the Department of Justice announced a $12.6 million settlement with Incyte Corporation, a Delaware...more
5/10/2021
/ Anti-Kickback Statute ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Frivolous Lawsuits ,
Healthcare Fraud ,
Kickbacks ,
Medicaid ,
Medicare ,
Money Laundering ,
Settlement ,
Telemarketing ,
TRICARE