“The Criminal Division is turning a new page on white-collar and corporate enforcement.” So pronounced the head of the US Department of Justice (DOJ) Criminal Division, Matthew Galeotti, in a recent speech rolling out several...more
The much-heralded end to prosecutions brought pursuant to the Foreign Corrupt Practices Act (FCPA) never materialized during the first Donald Trump administration, but Trump 2.0 has the potential to bring major change to the...more
On 23 September 2024, the DOJ announced another significant round of updates to its Evaluation of Corporate Compliance Programs (ECCP) – the guidance document Department of Justice (DOJ) prosecutors use to evaluate the...more
9/27/2024
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Compliance ,
Corporate Governance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Emerging Technologies ,
Enforcement Actions ,
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Risk Management ,
Whistleblower Protection Policies ,
Whistleblowers
A common approach in dealing with potential violations of the US export control laws is to undertake a voluntary disclosure to the regulators and thereby benefit from long-standing policies that favor such disclosure by...more
In a keynote address to the American Bar Association’s 2021 National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa O. Monaco outlined major changes to the U.S. Department of Justice’s (DOJ) priorities...more
In this second episode of our series on the government's response to the Paycheck Protection Program, white collar practitioners Chris Nasson, David Rybicki, Neil Smith, and Hayley Trahan-Liptak discuss the second phase of...more
This article analyzes emerging risks to PE firms that invest in the health care sector by examining the current enforcement landscape and significant FCA litigation; identifies key factors that increase FCA risk for PE firms...more
The U.S. Supreme Court’s 2019 decision in Azar v. Allina Health Services effectively curtailed the enforceability of certain Medicare policies established without notice-and-comment rulemaking. As a result, health care fraud...more