The first 120 days of the Trump administration have been characterized by dramatic changes in the realm of white-collar enforcement. However, in the midst of a period wrought with uncertainty over what the administration may...more
In our annual report, we examine health care enforcement trends, predict how health care enforcement may evolve, and offer practical guidance about what these trends and predictions mean for health care providers, payors, and...more
Over the past two years, the Department of Justice (DOJ or the Department) has actively incentivized companies to voluntarily self-disclose potential civil and criminal violations. For example, in 2023, in the criminal...more
1/17/2025
/ Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Healthcare Fraud ,
Non-Prosecution Agreements ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
On September 23, 2024, the Criminal Division of the United States Department of Justice (“DOJ” or the “Department”) revised its Evaluation of Corporate Compliance Programs guidance (the “ECCP”)....more
In March 2024, at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (“DAG”) Lisa Monaco announced that the Department of Justice (“DOJ” or the “Department”) intended to...more
8/16/2024
/ American Bar Association (ABA) ,
Audits ,
Bribery ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Financial Institutions ,
Forfeiture ,
Fraud ,
Incentives ,
Non-Prosecution Agreements ,
Pilot Programs ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more
Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more
4/25/2024
/ Compliance ,
Cooperation ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
FEPA ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
Healthcare Fraud ,
Incentives ,
Pilot Programs ,
Safe Harbors ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
White Collar Crimes
In early March 2024 at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco’s keynote remarks previewed the development of new and significant Department of...more
3/21/2024
/ American Bar Association (ABA) ,
CFTC ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Healthcare ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more
2/15/2024
/ Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement ,
False Claims Act (FCA) ,
Safe Harbors ,
Self-Disclosure Requirements ,
Settlement ,
Voluntary Disclosure ,
White Collar Crimes
2023 was a busy year across several federal agencies in terms of issuing compliance guidance for corporations, including health care companies. For example, the Department of Justice (DOJ) issued significant compliance...more
2/15/2024
/ American Bar Association (ABA) ,
Clawbacks ,
Compensation ,
Compliance ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
New Guidance ,
OIG ,
Risk Management ,
White Collar Crimes
In recent weeks, the Department of Justice has released key guidance in the form of a memorandum from Attorney General Garland regarding charging, pleas, and sentencing, in addition to an updated Corporate Enforcement Policy...more
2/6/2023
/ Attorney General ,
Cooperation ,
Department of Justice (DOJ) ,
FCPA Corporate Enforcement Policy (CEP) ,
Mail Fraud ,
Negotiations ,
Plea Agreements ,
Remediation ,
Self-Disclosure Requirements ,
Sentencing ,
White Collar Crimes ,
Wire Fraud