In the latest edition of our False Claims Act Guide: 2023 and the road ahead, we analyze the key developments from 2023 and discuss how the most important cases and issues are shaping FCA enforcement now and in the year to...more
2/14/2024
/ Anti-Kickback Statute ,
Cybersecurity ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Federal Contractors ,
Fraud ,
Health Care Providers ,
Medicaid ,
Popular ,
Private Equity Firms ,
Qui Tam
Last week at the 40th American Conference Institute (ACI) International Conference on the FCPA, government enforcement agencies such as the Department of Justice (DOJ), Securities and Exchange Commission (SEC), and UK Serious...more
Deputy Attorney General Lisa Monaco announces a new safe harbor policy for voluntary self-disclosures of acquired entities’ criminal misconduct. Although the new safe harbor provides clear timelines for disclosure, the costs...more
The Department of Justice (DOJ) recently issued a rare FCPA Opinion Procedure Release concerning travel of foreign government officials. Our lawyers analyze the opinion and highlight key considerations for companies engaged...more
The U.S. Departments of Commerce, Justice and Treasury have issued a “Tri-Seal” Compliance Note regarding national security laws and regulations and the voluntary self-disclosure of potential violations, highlighting...more
8/2/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure
This month, the Department of Justice (DOJ) announced various policy changes meant to promote corporate compliance and update DOJ’s “Evaluation of Corporate Compliance Programs.” This article discusses two of these policy...more
On January 17, 2023, the Department of Justice (DOJ) rolled out revisions to its Corporate Enforcement Policy (CEP) aimed at incentivizing companies to voluntarily self-disclose misconduct and to cooperate with government...more
The American Bar Association’s annual white collar crime conference is often a favorite place for the U.S. Department of Justice to announce new policies and programs, and this year’s meeting in San Francisco was no...more
Through Aerospace & Defense Insights, we share with you the top legal and political issues affecting the aerospace and defense (A&D) industry. Our A&D industry team monitors the latest developments to help our clients stay in...more
On January 21, 2022, the Department of Justice (“DOJ”) issued a Foreign Corrupt Practices Act (“FCPA”) Opinion Procedure Release (the “OPR” or “OPR 22-01”) addressing the rarely discussed extortion exception to the FCPA’s...more
In the latest edition of our False Claims Act Guide: 2021 and the road ahead, we analyze the key developments from 2021 and discuss how the most important cases and issues are shaping FCA enforcement now and in the year to...more
The Biden-Harris Administration intensified its focus on combating corruption by issuing the first-ever United States Strategy on Countering Corruption (“USSCC”) on December 6, 2021. This Strategy followed the...more
There has been significant movement recently, by both the Biden Administration as well as Congress, to enhance the U.S. government’s ability to tackle corruption. This article provides a summary of those efforts and several...more
6/17/2021
/ AML/CFT ,
Anti-Corruption ,
BSA/AML ,
Corporate Counsel ,
Corruption ,
Financial Crimes ,
Human Trafficking ,
Joint Task Force ,
National Security ,
Policy Statement ,
Smuggling ,
White Collar Crimes
The federal government’s recoveries from investigations and cases involving the False Claims Act (FCA) fell in fiscal year (FY) 2020 to US$2.2 billion from US$3.05 billion in FY2019. However, with an influx of approximately...more
3/16/2021
/ Aerospace ,
Aviation Industry ,
Biden Administration ,
Construction Project ,
Critical Infrastructure Sectors ,
Defense Sector ,
Engineering ,
False Claims Act (FCA) ,
Federal Contractors ,
Goods or Services ,
Information Technology ,
Shipping ,
Software ,
Supply Chain
On June 1, 2020, the U.S. Department of Justice (DOJ), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs,” providing increased clarity on some of the key questions prosecutors will...more
On 13 December 2019 the U.S. Department of Justice's (DOJ) National Security Division (NSD) announced the release of its long-anticipated and updated Export Control and Sanction Enforcement Policy for Business Organizations...more
12/19/2019
/ Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Authority ,
Export Controls ,
FCPA Guidance ,
National Security ,
Policy Statement ,
Sanction Violations ,
Self-Reporting ,
Trade Relations ,
Willful Misconduct
On November 20, 2019, the U.S. Department of Justice (DOJ) announced several subtle, but important, adjustments to its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. These recent changes relate to...more
In a May 17, 2019 press report that has been widely distributed in Brazil and the United States, Brazilian Federal Prosecutor Marisa Ferrari confirmed that the U.S. Federal Bureau of Investigation (FBI), the U.S. Department...more
5/21/2019
/ Brazil ,
Bribery ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FBI ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Kickbacks ,
Medical Devices ,
Multinationals ,
Pharmaceutical Industry ,
Popular ,
Price-Fixing ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
New guidance issued by the U.S. Department of Justice (DOJ) is the latest confirmation of the importance of implementing a robust compliance program that is not simply well-designed, but also effective....more