The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more
Equality under the law is a cardinal principle of the United States’ constitutional order. This principle extends to laws regulating speech. Specifically, the government does not get to single out a particular viewpoint and...more
In the past five years, the Federal Government and “Qui Tam” Realtors have ramped up False Claims Act (“FCA”) actions against higher education institutions. These actions highlight the scope and breadth of potential FCA...more
1/23/2024
/ Colleges ,
Compliance ,
Cybersecurity ,
Department of Justice (DOJ) ,
Enforcement ,
False Claims Act (FCA) ,
False Statements ,
Fraud ,
Liability ,
Medicaid ,
Medicare ,
Title IV ,
Universities
In recent memory, enforcement of the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) regulations has been mostly limited and sporadic. But recently, the U.S. government is reviving and...more
1/22/2024
/ Acquisitions ,
Buyers ,
CFIUS ,
Compliance ,
Due Diligence ,
Enforcement ,
Executive Orders ,
Export Controls ,
FIRRMA ,
Foreign Investment ,
Infrastructure ,
Mergers ,
Sellers ,
U.S. Treasury
The Department of Commerce (the “Department”) announced the launch of the first Notice of Funding Opportunity (“NOFO”) under the CHIPS Act’s incentive program. This program aims to strengthen the U.S. semiconductor supply...more
3/7/2023
/ CFIUS ,
Compliance ,
Export Controls ,
False Claims Act (FCA) ,
Federal Grants ,
FOCI ,
Funding ,
Incentives ,
Loans ,
Manufacturers ,
Semiconductors ,
U.S. Commerce Department
Whether or not a client is involved in civil litigation, the target of a grand jury subpoena or some other request to produce documents, the attorney-client privilege serves as a powerful tool to shield sensitive matters from...more
The ability to petition one’s leaders is long recognized regardless of the form of government. Ever since the Watergate Scandal, the United States has taken the lead on transparency in governmental acts and the interaction...more
Arizona is one of the most progressive states when it comes to citizen led initiatives to create or change (and literally enshrine) laws. However, the procedure to put such initiatives to vote are largely controlled by the...more
With the ever-increasingly complex regulatory environment in the United States, ensuring corporate compliance is neither inexpensive nor easy. Given these difficulties, when the need to conduct an internal investigation...more
On November 10, the Biden Administration proposed the Federal Supplier Climate Risks and Resilience Rule (the “Proposed Rule”). The Proposed Rule would amend the Federal Acquisition Regulations and requires federal...more
In a highly anticipated speech, Deputy Attorney General Lisa O. Monaco delivered remarks outlining updates to the U.S. Department of Justice (“DOJ”) perspective on the Corporate Crime Enforcement policy. These updates are the...more
The Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) have recently stepped up the pressure on virtual currency companies. Increased regulatory scrutiny has largely taken the...more
Government contractors and other companies subject to internal investigation requirements won some relief from the United States Court of Appeals for the D.C. Circuit on June 26 with a decision that firmly reiterated that...more
7/1/2014
/ Appeals ,
Attorney-Client Privilege ,
Compliance ,
Confidential Communications ,
Contractors ,
Employer Liability Issues ,
False Claims Act (FCA) ,
Federal Contractors ,
Internal Investigations ,
KBR (formerly Kellogg Brown & Root) ,
Upjohn Warnings ,
Work-Product Doctrine
Governments in every country are taking international trade compliance seriously. Unlike other company departments that heavily rely on automation to track supply chain compliance, those departments responsible for...more
The Global Connection has extensively covered the U.S. Foreign Corrupt Practices Act (“FCPA”) over the years. With the advent of the U.K. Bribery Act, the FCPA was finally having real competition by another country as a...more
In the shadow of billion dollar settlements, exhaustive and expensive internal investigations, costly shareholder derivative suits, and the constant need to stay competitive in a global marketplace, companies in recent years...more
The Export Control Reform (“ECR”) initiative is in full swing. On October 15, 2013, businesses will wake up operating under a completely revised export control system. Some the changes have been in works for several years,...more
On Friday, March 1, 2013, the parent company of the Las Vegas Sands Corp. (Sands), reported in a filing to the Securities and Exchange Commission (SEC) that the company may have violated the “books and records and internal...more
On November 8, 2012, we opined in the Global Connection as to what to expect from the anticipated Department of Justice (DOJ) and Securities Exchange Commission (SEC) guidance in regard to the Foreign Corrupt Practices Act...more