Issued on February 10, 2025, Executive Order 14209 (“Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security”) called on the Department of Justice (DOJ) to “review guidelines and...more
6/13/2025
/ Anti-Corruption ,
Bribery ,
Cartels ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Government Agencies ,
Internal Investigations ,
National Security ,
New Guidance ,
White Collar Crimes
According to a memorandum issued on May 19, 2025, the Department of Justice (“DOJ”) will use the False Claims Act as a tool to enforce federal civil rights laws. The new policy memo has serious potential implications for...more
5/27/2025
/ Civil Rights Act ,
Colleges ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Educational Institutions ,
Executive Orders ,
False Claims Act (FCA) ,
Federal Funding ,
Students for Fair Admissions v Harvard College ,
Title IV ,
Title IX ,
Title VI ,
Universities
On February 10, 2025, President Trump issued an executive order that instructed DOJ to pause all action related to enforcement of the Foreign Corrupt Practices Act (FCPA). Enacted in 1977, the FCPA features anti-bribery...more
2/19/2025
/ Anti-Corruption ,
Compliance ,
Corporate Governance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
Trump Administration
The False Claims Act imposes liability for false and fraudulent claims a defendant submitted with the requisite state of mind, or scienter. Before the Supreme Court handed down its June 1, 2023, decision in the combined...more
6/8/2023
/ Drug Pricing ,
False Claims Act (FCA) ,
Healthcare ,
Pharmaceutical Industry ,
Pharmacies ,
Prescription Drugs ,
Reasonable Interpretations ,
Scienter ,
SCOTUS ,
US ex rel Thomas Proctor v Safeway Inc ,
US ex rel Tracy Schutte et al v SuperValu Inc et al
On May 10, 2023, the First Circuit dealt a major blow to the Department of Justice’s wide-ranging "Varsity Blues" investigation by reversing convictions of two defendants. Individuals, companies, and federal contractors in...more
Last week, Deputy Attorney General Lisa Monaco’s statements to the American Bar Association again highlighted the fact that investigating and prosecuting individuals for violating economic sanctions, export controls, and...more
3/7/2023
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Justice (DOJ) ,
DOJ Strike Force ,
Economic Sanctions ,
Enforcement Priorities ,
Export Controls ,
FBI ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Foreign Assets Control (OFAC)
In a speech given at NYU on September 15, 2022, Deputy Attorney General Lisa Monaco reviewed new and enhanced Department of Justice (DOJ) policies regarding criminal enforcement related to corporate entities. Assistant...more