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New DOJ Task Force Will Scrutinize Health Care Industry for Antitrust Issues

A new federal antitrust task force will focus on investigations in health care markets, and, where warranted, civil and criminal enforcement, the Department of Justice announced....more

DOJ launches whistleblower pilot program and cracks down on artificial intelligence misuse

Following a year of new DOJ policies and guidance designed to incentivize companies to self-report misconduct and to cooperate with government investigations, the DOJ has added a new pilot whistleblower rewards program. In...more

DOJ Launches Whistleblower Pilot Program and Cracks Down on AI Misuse

The Department of Justice (DOJ) has unveiled a new whistleblower policy designed to incentivize individuals to disclose corporate misconduct through financial rewards from any resulting forfeiture of criminal proceeds. The...more

DOJ Bolsters International Cooperation to Combat Corruption

Summary - The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...more

Safe Harbor Policy Incentivizes Disclosure of Acquired Companies’ Misconduct

Summary - Deputy Attorney General Lisa O. Monaco unveiled Wednesday, Oct. 4, the Department of Justice’s (DOJ) new safe harbor policy for voluntary self-disclosures (VSD) arising from mergers and acquisitions (Safe Harbor...more

DOJ Appoints New Leaders of Corporate Enforcement Program

Summary - The Department of Justice’s creation of two new leadership positions within the National Security Division (NSD) sends another strong signal to the private sector that federal law enforcement is pouring resources...more

DOJ Announces New Policies on Clawbacks and Business-Related Communications

Summary - Top U.S. Department of Justice officials announced the DOJ’s first-ever pilot program on corporate compensation incentives and clawbacks, as well as new policies on preservation of corporate communications, at...more

DOJ's Revisions to the Corporate Enforcement Policy Incentivize Self-Reporting of Misconduct

Summary - The Department of Justice (DOJ) last week issued revisions to the Criminal Division’s Corporate Enforcement Policy that incentivize companies to promptly self-disclose corporate misconduct, cooperate with the DOJ,...more

United States v. Banks: The Third Circuit Weighs in on Calculating Loss Enhancements Under U.S.S.G. § 2B1.1

Summary - The Third Circuit’s recent opinion in United States v. Banks changes how loss calculations impact sentencing guidelines under U.S.S.G. § 2B1.1, the Federal Sentencing Guidelines that govern the vast majority of...more

New DOJ Memo Includes Significant Changes to Corporate Crime Policies

Summary - A new memorandum from Deputy Attorney General Lisa Monaco, released on September 15 (Memorandum), represents one of the most comprehensive updates in years to the approach of the U.S. Department of Justice (DOJ) in...more

The Tokyo Olympic Games and Increased Anti-Doping Enforcement

Summary - The Tokyo Olympics is the United States’ first opportunity to target and prosecute doping conspiracies under the Rodchenkov Anti-Doping Act (Rodchenkov Act), an act that criminalizes conspiracies surrounding the...more

President Biden Unveils Broad Vision to Crackdown on Foreign and Domestic Corruption

Agenda Highlights Intersection of National Security, Corruption and Anti-Money Laundering - On June 3, 2021, President Biden unveiled a National Security Study Memorandum entitled Memorandum on Establishing the Fight...more

SEC and DOJ Target Insider Trading on the Dark Web

The U.S. Securities and Exchange Commission (SEC) and the U.S. Department of Justice (DOJ) brought actions against SpaceX engineer James Roland Jones for selling insider information on what’s known as the dark web....more

Investment Advisers May Be Subject to AML Regulations Under Revival of Proposed Rule

Bottom Line: Biden Administration May Revive FinCEN’s Proposed Rule For Investment Advisers - Unlike broker-dealers, investment advisers are not currently required to maintain anti-money laundering...more

DOJ Updates Guidance on the Evaluation of Corporate Compliance Programs

The Department of Justice-Criminal Division recently updated its internal guidance to federal prosecutors for evaluating corporate compliance programs. The DOJ does not promulgate a checklist or formula for evaluating such a...more

Consumer lender sets aside $21.7 million to settle Foreign Corrupt Practices Act probe

South Carolina-based consumer lender World Acceptance Corporation announced recently that it had earmarked $21.7 million to resolve a Securities and Exchange Commission (SEC) probe into its compliance with the Foreign Corrupt...more

PPP Participants Should Prepare For Vigorous Oversight

With significant government intervention comes significant government oversight. That is the message coming from Capitol Hill and the Executive Branch concerning the Payroll Protection Program (PPP), a Small Business...more

The CARES Act: Oversight Provisions

The Coronavirus Aid, Relief and Economic Security Act (Act), an unprecedented spending package aimed at alleviating the economic impact of the coronavirus pandemic, passed Congress today. We focus here on the Act’s oversight...more

False Claims and Coronavirus: Prevent the Spread of Fraud

On March 16, the National Whistleblower Center (NWC) called on Attorney General William Barr to form a nationwide task force to monitor and investigate False Claims Act (FCA) allegations related to the Covid-19 pandemic....more

DOJ Indicts Professor and Drug Trafficking Expert for Laundering Proceeds of Venezuelan Corruption Scheme

A Textbook Case of Alleged Money Laundering? On November 18, 2019, the U.S. Attorney for the Southern District of New York announced the arrest and unsealed the indictment of Bruce Bagley – a 73-year-old college professor...more

DOJ Announces Restructuring Within Fraud Section

Assistant Attorney General Brian A. Benczkowski announced the restructuring of the U.S. Department of Justice’s Securities and Financial Fraud Unit within the Fraud section of the Criminal Division. The unit will now be known...more

DOJ Updates Guidance on Evaluating Corporate Compliance Programs

The U.S. Department of Justice-Criminal Division recently updated its internal guidance to federal prosecutors for evaluating corporate compliance programs....more

FBI Establishes Anti-Corruption Team in Miami

In recognition of the significance South America has played in recent FCPA enforcement, yesterday the FBI announced that it will establish a team of agents in Miami focused on FCPA cases in Miami and South America. ...more

Deputy AG Rosenstein Announces New DOJ Policies to Reduce 'Piling On' and Refocus Corporate Enforcement

In a highly anticipated speech to the New York City Bar White Collar Crime Institute this morning, Deputy Attorney General Rod Rosenstein announced two new Department of Justice (DOJ) policies...more

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