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New Executive Order Directs DOJ to Pause FCPA Enforcement

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

Supreme Court Rejects an Objective Standard for False Claims Act Inquiries

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

"Varsity Blues" Reversal Demonstrates Limitations of Conspiracy Allegations

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

Recent Actions Illustrate Continued Focus on Export Control Violations

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

DOJ's New Policies Encourage Voluntary Self-Disclosure, Compensation Tied to Compliance

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

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