On January 20, 2025, President Donald J. Trump signed Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists” (EO 14157)....more
4/23/2025
/ Anti-Money Laundering ,
Cartels ,
Civil Liability ,
Corporate Liability ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
SDN List ,
Significant Transnational Criminal Organization ,
Terrorist Organizations
In a groundbreaking opinion issued on September 30, 2024, Judge Kathryn Kimball Mizelle of the U.S. District Court for the Middle District of Florida dismissed a False Claims Act (FCA) lawsuit, holding that the qui tam...more
As recent developments in corporate enforcement indicate, the United States Department of Justice (DOJ) continues to emphasize transparency, cooperation, and the importance of a strong compliance program. Enforcement trends...more
11/20/2020
/ Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Culture ,
Corporate Integrity Agreement ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Health Care Providers ,
Healthcare Fraud ,
Strategic Enforcement Plan
Last week, the United States Department of Justice (“DOJ”) announced the creation of the National Rapid Response Strike Force (“NRR Strike Force”) within the DOJ’s Health Care Fraud Unit. The announcement was made in...more
On October 8, 2019, the US Department of Justice (DOJ or Justice Department) issued new guidance on evaluating inability-to-pay arguments in a memorandum to the Criminal Division. The memorandum provides considerably more...more
10/11/2019
/ Corporate Counsel ,
Corporate Crimes ,
Corporate Criminal Fines ,
Corporate Misconduct ,
Criminal Penalties ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Failure To Pay ,
Federal Sentencing Guidelines ,
New Guidance ,
White Collar Crimes
On May 6, 2019, the Justice Department issued new policies establishing how defendants in False Claims Act (FCA) matters can earn credit for voluntary self-disclosure, cooperation, and remediation, possibly reducing what...more
5/8/2019
/ Compliance ,
Cooperation ,
Damages ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
New Guidance ,
Penalties ,
Remediation ,
Scienter ,
Voluntary Disclosure
As reflected in recent remarks by Deputy Attorney General Rod Rosenstein, the United States Department of Justice (DOJ) is “reinforcing its relationship with good corporate citizens” by coordinating with, and considering, the...more
3/18/2019
/ Anti-Kickback Statute ,
Code of Conduct ,
Corporate Integrity Agreement ,
Corporate Misconduct ,
Criminal Investigations ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Frivolous Lawsuits ,
New Guidance ,
OIG ,
Relators ,
The Granston Memo
On October 12, 2018 in remarks made at the NYU School of Law Program on Corporate Compliance and Enforcement’s Conference on Achieving Effective Compliance, Assistant Attorney General for the U.S. Department of Justice...more
On January 25, Associate Attorney General Rachel Brand issued a memorandum to all components of the Department of Justice with civil litigating authority limiting the use of agency guidance documents in affirmative civil...more
On January 10, the head of the Justice Department's Civil Frauds Section issued an internal memorandum instructing all Department attorneys handling False Claims Act (FCA) cases to consider whether, when declining to...more