A recent suit illustrates how whistleblowers may adversely impact a company’s DPA, leading to further investigation by the DOJ and additional penalties.
In 2023, Connecticut-based Freepoint Commodities LLC (Freepoint)...more
10/23/2025
/ Anti-Corruption ,
Bribery ,
CFTC ,
Compliance ,
Cooperation Agreement ,
Corporate Governance ,
Criminal Conspiracy ,
Criminal Investigations ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
Indictments ,
Penalties ,
Whistleblower Awards ,
Whistleblowers
In May 2025, the Department of Justice (“DOJ”) announced changes to its corporate enforcement policies, including revisions to the Criminal Division’s standards for the selection and use of monitors....more
9/23/2025
/ Corporate Governance ,
Corporate Misconduct ,
Corporate Monitoring ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Internal Controls ,
New Guidance ,
Policies and Procedures ,
Regulatory Oversight ,
Risk Management ,
White Collar Crimes
This article recaps Department of Justice guidance since the Trump Administration took office in January. These are topics we’ve addressed in previous articles and alerts, and are presented here in summarized form....more
8/29/2025
/ Compliance Monitoring ,
Corporate Investigations ,
Corporate Misconduct ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
False Claims Act (FCA) ,
Internal Controls ,
Non-Prosecution Agreements ,
Self-Disclosure Requirements ,
Trump Administration ,
Voluntary Disclosure ,
White Collar Crimes
Heath care fraud remains a top priority for the DOJ. This year’s National Health Care Fraud Takedown was the biggest in United States history, resulting in the prosecution of 324 defendants in connection with over $14.6...more
8/27/2025
/ Banking Sector ,
C-Suite Executives ,
Civil Investigation Demand ,
Continuing Legal Education ,
Criminal Investigations ,
Cybersecurity ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Grand Juries ,
Health Care Providers ,
Health Clinics ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare Facilities ,
Healthcare Fraud ,
Hospitals ,
Laboratories ,
Money Laundering ,
OIG ,
Pharmaceutical Industry ,
PHI ,
Popular ,
Skilled Nursing Facility ,
Subpoenas ,
Webinars ,
White Collar Crimes
A recent whistleblower suit could impact a company’s deferred prosecution agreement (“DPA”) potentially leading to further investigation by DOJ and additional penalties.
A whistleblower suit was recently filed in the New...more
8/20/2025
/ Anti-Retaliation Provisions ,
CFTC ,
Compliance Monitoring ,
Corporate Counsel ,
Corporate Governance ,
Declination ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Insider Trading ,
NY Supreme Court ,
Retaliation ,
Self-Reporting ,
Whistleblowers
Join us for an informative webinar providing the latest updates on key compliance issues under the current administration. Our panel will address recent developments in tariffs, the FCPA, False Claims Act, and sanctions....more
7/10/2025
/ Compliance ,
Continuing Legal Education ,
Corporate Counsel ,
Corporate Crimes ,
Criminal Liability ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Priorities ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
New Guidance ,
Risk Management ,
Tariffs ,
Webinars ,
White Collar Crimes
On June 30, 2025, the Department of Justice announced the results of its 2025 National Health Care Fraud Takedown (“2025 Takedown”). ...more
7/7/2025
/ Bank Secrecy Act ,
Centers for Medicare & Medicaid Services (CMS) ,
Cryptocurrency ,
Cybersecurity ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Fraud ,
Healthcare Fraud ,
Medicaid ,
Medicare ,
Money Laundering ,
Whistleblowers
Two recent Supreme Court matters signal major implications for government contractors. First, the Supreme Court will review whether government contractors can appeal a denial of a sovereign immunity defense in lawsuits...more
6/23/2025
/ Contract Disputes ,
Criminal Conspiracy ,
Criminal Liability ,
Defense Strategies ,
Federal Contractors ,
Forced Labor ,
Fraud ,
Immigration and Customs Enforcement (ICE) ,
Litigation Strategies ,
SCOTUS ,
Sovereign Immunity ,
Trafficking ,
Wire Fraud
The Department of Justice ("DOJ") recently announced new guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (FCPA). ...more
DOJ recently announced white-collar crime enforcement priorities and significant changes to its corporate enforcement policies (here and here). “[O]verbroad and unchecked corporate and white-collar enforcement burdens U.S....more
Foreign regulators continue to intensify their efforts to combat bribery and corruption. France’s Anti-Corruption Agency (L’Agence française anticorruption or AFA) recently published its year-in-review for 2024, which showed...more
5/1/2025
/ Anti-Corruption ,
Bribery ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
Enforcement Authority ,
Enforcement Statistics ,
France ,
Multinationals ,
New Guidance ,
Regulatory Requirements ,
Serious Fraud Office (SFO) ,
UK
Effective September 1, 2025, the UK’s Failure to Prevent Fraud offense will go into effect as part of the UK’s Economic Crime and Corporate Transparency Act 2023 (the ECCTA). The law significantly expands corporate liability...more
4/23/2025
/ Anti-Corruption ,
Compliance ,
Compliance Dates ,
Corporate Liability ,
Enforcement Priorities ,
EU ,
Failure to Prevent ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
New Legislation ,
Risk Management ,
UK
With increasing digitalization of our lives and businesses, privacy concerns from border searches of phones, laptops and tables are a growing concern for professionals, executives, and frequent international travelers. U.S....more
4/21/2025
/ Border Searches ,
Constitutional Challenges ,
Customs and Border Protection ,
Data Privacy ,
Department of Homeland Security (DHS) ,
Electronic Devices ,
Foreign Nationals ,
Fourth Amendment ,
International Travel ,
Mobile Devices ,
Privacy Laws ,
Risk Management ,
Traveling Employee ,
Visas
On February 5, 2025, Attorney General Pamela Bondi issued a memo requiring DOJ’s Foreign Corrupt Practice Act (“FCPA”) Unit to “prioritize investigations related to foreign bribery that facilitates the criminal operations of...more
3/25/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Cross-Border ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Joint Task Force ,
Serious Fraud Office (SFO) ,
Significant Transnational Criminal Organization ,
Switzerland ,
Trump Administration ,
UK
On January 20, President Trump issued an Executive Order designating certain international cartels as Foreign Terrorist Organizations (FTOs) or Specially Designated Global Terrorists (SDGTs). ...more
2/24/2025
/ Anti-Corruption ,
Bribery ,
Cartels ,
Compliance ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Risk Management ,
Significant Transnational Criminal Organization ,
Terrorist Organizations
The Fraud Section of the U.S. Department of Justice’s Criminal Division published its Year in Review last month, which showed an uptick for white collar enforcement in foreign corruption, financial and health care fraud. The...more
2/4/2025
/ Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Statistics ,
False Claims Act (FCA) ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Healthcare Fraud ,
Securities Fraud ,
Whistleblowers ,
White Collar Crimes
Latin America has been the focus of considerable attention by the DOJ. Despite strong ties based on trade, shared values and democratic traditions, Latin America is being tested with new and precarious challenges from...more
11/5/2024
/ Anti-Corruption ,
Biden Administration ,
Department of Justice (DOJ) ,
Enforcement ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Latin America ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Webinars ,
White Collar Crimes
Latin America has been the focus of considerable attention by the Biden Administration and the DOJ. Despite strong ties based on trade, shared values and democratic traditions, Latin America is being tested with new and...more
10/8/2024
/ Anti-Corruption ,
Biden Administration ,
Department of Justice (DOJ) ,
Enforcement ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Latin America ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Webinars ,
White Collar Crimes
On September 23, 2024, the Criminal Division of the U.S Department of Justice (“DOJ”) released revised Evaluation of Corporate Compliance Programs guidance (“September 2024 Guidance), last updated in March 2023....more
9/27/2024
/ Chief Compliance Officers ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Guidance Update ,
Pilot Programs ,
Reporting Requirements ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
Two recent court Foreign Corrupt Practices Act (FCPA) cases, a significant amendment to the Foreign Extortion Prevention Act (FEPA), and the new pilot whistleblower rewards program show that Anti-Corruption Enforcement...more
8/22/2024
/ Anti-Corruption ,
Bribery ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Federal Pilot Programs ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Government Investigations ,
Latin America ,
South Africa ,
Whistleblower Awards ,
Whistleblowers
The U.S. Department of Justice’s (“DOJ”) Criminal Division announced its new Corporate Whistleblower Awards Pilot Program on August 1, 2024. The Pilot Program incentivizes whistleblowers to provide information to the DOJ so...more
8/8/2024
/ CFTC ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On June 26, 2024, the U.S. Supreme Court issued an opinion in a public corruption case that could have a lasting impact on how the U.S. Government prosecutes corruption and procurement fraud cases involving state and local...more
7/5/2024
/ Bribery ,
Compliance ,
Corruption ,
Criminal Convictions ,
Criminal Prosecution ,
Illegal Gratuities ,
Political Corruption ,
Public Corruption ,
Public Officials ,
Public Procurement Policies ,
SCOTUS ,
Snyder v United States ,
Split of Authority ,
Tips
On May 9, 2024, the Antitrust Division of the Department of Justice (DOJ) announced a new Task Force on Health Care Monopolies and Collusions (HCMC). Comprised of civil and criminal prosecutors, economists, healthcare...more
5/22/2024
/ Acquisitions ,
Analytics ,
Antitrust Division ,
Books & Records ,
Collusion ,
Competition ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Health Care Providers ,
Mergers ,
Monopolization ,
Risk Management ,
Safe Harbors ,
Voluntary Disclosure
In the U.S. Department of Justice’s (DOJ) latest policy in furtherance of its “carrots and sticks” approach to corporate criminal enforcement, senior leadership of its Criminal Division announced a new Pilot Program on...more
On April 17, 2024, the House Education and Workforce Committee is scheduled to hold a hearing to focus on Antisemitism in Higher Education. At the witness table will be the President of Columbia University Dr. Nemat...more
4/17/2024
/ Bias ,
Civil Rights Act ,
Colleges ,
Colombia ,
Congressional Committees ,
Congressional Investigations & Hearings ,
Department of Education ,
Educational Institutions ,
Investigations ,
OCR ,
Title VI ,
Universities