On May 12, 2025, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, gave a speech at SIFMA’s Money Laundering and Financial Crimes Conference that previewed subsequently issued policy changes impacting the Criminal...more
5/16/2025
/ Anti-Money Laundering ,
Corporate Culture ,
Corporate Governance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Policies and Procedures ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
The Foreign Corrupt Practices Act (FCPA), passed in the wake of Watergate, prohibits U.S.-linked companies and individuals from bribing foreign government officials to procure international business and hiding the bribes in...more
A defendant’s knowledge of and subjective beliefs about the meaning of legal requirements—not what an objectively reasonable person may have believed—are what matters when determining whether a defendant “knowingly” submitted...more
6/6/2023
/ Drug Pricing ,
False Claims Act (FCA) ,
Fraud ,
Healthcare ,
Oral Argument ,
Pharmaceutical Industry ,
Pharmacies ,
Prescription Drugs ,
Reasonable Interpretations ,
Safeco ,
Safeco Insurance Co of America v Burr ,
Scienter ,
SCOTUS ,
US ex rel Thomas Proctor v Safeway Inc ,
US ex rel Tracy Schutte et al v SuperValu Inc et al
The U.S. Department of Justice (DOJ) on March 3, 2023, unveiled a new pilot program and announced several important updates to its Evaluation of Corporate Compliance Programs (ECCP) regarding corporate compensation incentives...more
3/21/2023
/ Clawbacks ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Compensation ,
Guidance Update ,
Incentives ,
Pilot Programs ,
White Collar Crimes
The U.S. Department of Justice (DOJ) obtained more than $2.2 billion in civil False Claims Act (FCA) judgments and settlements in fiscal year (FY) 2022, the lowest such annual total since 2008 and a significant drop from a...more
2/10/2023
/ Business Litigation ,
Coronavirus/COVID-19 ,
Cybersecurity ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Healthcare ,
Qui Tam ,
Relators ,
Settlement ,
Whistleblowers ,
White Collar Crimes
In United States ex rel. Wollman v. Massachusetts Gen. Hosp., Inc., No. CV 15-11890-ADB, 2020 WL 4352915 (D. Mass. July 29, 2020), yet another district court agreed with the U.S. Court of Appeals for the District of Columbia...more
The world changed in 2020. Many of the activities formerly conducted in person now occur remotely and will likely occur remotely for the foreseeable future. This includes depositions, interviews, and other forms of testimony....more
The U.S. Supreme Court handed down an important decision on June 16, 2016 that expands the scope of liability under the False Claims Act, 31 U.S.C. §§ 3729-3733, (the FCA). In Universal Health Services, Inc. v. United...more
The U.S. Supreme Court is poised to resolve a circuit split over the False Claims Act (FCA) that could have broad implications for those that do business with the federal government. On April 19, 2016, the Supreme Court...more