The U.S. Attorney's Offices (USAOs) Voluntary Self-Disclosure Policy, announced on Feb. 22, 2023, sets forth a nationwide standard for how USAOs will define and credit corporate self-disclosures of misconduct by employees or...more
The U.S. Department of Justice (DOJ), through Assistant Attorney General Kenneth A. Polite Jr., announced on Jan. 17, 2023, "the first significant changes" to its Corporate Enforcement Policy (CEP) since 2017. The revisions...more
1/23/2023
/ Compliance ,
Cooperation ,
Corporate Misconduct ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Declination ,
Department of Justice (DOJ) ,
Enforcement ,
Federal Sentencing Guidelines ,
Policy Updates ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
DOJ Releases Guidance on Cooperation Credit in False Claims Act Cases -
The U.S. Department of Justice (DOJ) released guidelines for evaluating self-disclosures and awarding cooperation credit in False Claims Act (FCA)...more
Companies facing liability under the False Claims Act (FCA) often desire early resolution with the Department of Justice (DOJ) through settlement. Hand in hand with the decision to settle comes the decision of whether or not...more
4/26/2019
/ Cooperation ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Sentencing Guidelines ,
Fraud ,
Qui Tam ,
Regulatory Requirements ,
Remedial Actions ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Self-Policing ,
Self-Reporting
Most practitioners are aware that the statute of limitations under the False Claims Act (FCA) is six years after the date on which the violation is committed. 31 U.S.C. § 3731(b)(1). That is, unless the FCA’s tolling...more
5/2/2018
/ Department of Justice (DOJ) ,
Dismissals ,
False Claims Act (FCA) ,
Federal Contractors ,
First-to-File ,
Frivolous Lawsuits ,
Government Officials ,
OIG ,
Qui Tam ,
Real Party in Interest ,
Self-Disclosure Requirements ,
Statute of Limitations ,
Time-Barred Claims ,
Tolling Provisions