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The Trump Administration Takes Aim at Regulatory Overcriminalization

On May 9, 2025, President Donald Trump issued an Executive Order entitled “Fighting Overcriminalization in Federal Regulations.” The Order takes aim at what the President calls “regulatory crimes,” with the intended purpose...more

Hidden in the NDAA: The Expanded Reach of the Program Fraud Civil Remedies Act

Federal government contractors and many others have been closely watching the drafting, introduction, consideration, debate, amendment, and passage of the annual National Defense Authorization Act (“NDAA”)....more

The Company You Keep: FCA Investigations of 8(a) Program Contractors

Federal government contracts are routinely awarded to companies supplying goods and services to U.S. government agencies. According to the Government Accountability Office, in 2023, the federal government committed about $759...more

DOJ Debuts Pilot Corporate Whistleblower Awards Program

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

Supreme Court Resolves Circuit Split and Finds Federal Gratuities Inapplicable to State and Local Officials

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

Criminal Division of U.S. Department of Justice Announces Pilot Program on Voluntary Self-Disclosure for Individuals

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

IRS Continues Aggressive Oversight and Enforcement of Employee Retention Credits

The Employee Retention Credit (ERC) is a refundable tax credit for businesses whose employees were impacted by the COVID-19 Pandemic. The provisions are set out in § 2301 of the CARES Act and § 3111 of the Internal Revenue...more

Current Trends and Real-World Best Practices in Healthcare Fraud Compliance

Recently, Womble Bond Dickinson held its First Annual Health Care Fraud Symposium, a webinar designed to discuss critical healthcare fraud topics. WBD Partner Joe Whitley moderated a discussion with WBD attorneys Luke Cass,...more

With Great ‘Empowerment’ Comes Great Responsibility (and Risk) for CCOs Under Monaco Memo

The Monaco memo’s imposition of CCO certification in DOJ investigations has, reasonably, been a major anxiety-inducer for compliance professionals. And while DOJ officials have said the requirement is designed to “empower”...more

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