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DOJ’s White Collar Enforcement Priorities: What’s In, What’s Out

On May 12, the Criminal Division of the U.S. Department of Justice (DOJ) issued a series of changes in its white collar enforcement priorities. These changes were announced in the Criminal Division Enforcement Plan, the...more

Undervalue at Your Own Risk: The False Claims Act Comes for Imports

While some enforcement areas have taken a pause this year, False Claims Act enforcement—especially around customs duties—is moving and likely to get busier. Just last week the U.S. Department of Justice filed a complaint...more

Pausing Bribery Prosecutions: What Companies Need to Know

Last week President Trump signed an Executive Order pausing enforcement of the nation’s most robust anti-bribery statute, the Foreign Corrupt Practices Act (“FCPA”). The EO seeks a complete overhaul of the FCPA enforcement...more

Introducing the Government and Regulatory Rundown – March 2023

DOJ Promotes Compliance Through Compensation and Clawback Programs (3.2.2023): • The DOJ announced corporate criminal resolutions will now include a requirement that companies implement a compensation and bonus scheme...more

CEO of Publicly Traded Health Care Company Charged with Insider Trading For Misusing Rule 10b5-1 Trading Plans

On March 1, 2023, the U.S. Department of Justice (“DOJ”) unsealed an indictment charging Terren S. Peizer, the CEO and Chairman of the Board of Directors of Ontrak Inc., a publicly traded health care company, with engaging in...more

DOJ Releases New Voluntary Self-Disclosure Policy

On February 22, 2023, the Department of Justice (“DOJ”) released a new voluntary self-disclosure (“VSD”) policy (available here) that applies to all United States Attorney’s Offices (“USAO”). The policy details the...more

DOJ’s Revised Corporate Criminal Enforcement Policies Encourage Voluntary Disclosure and Focus on Compensation

On September 15, 2022, Deputy Attorney General Lisa O. Monaco announced new Department of Justice (“DOJ”) policies on corporate criminal enforcement. DOJ designed the new policies based on recommendations by the Corporate...more

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