Despite signs of a retrenchment in some of the traditional areas of white collar enforcement under the Trump administration, the U.S. Department of Justice’s (“DOJ”) enforcement of the civil False Claims Act (“FCA”) appears...more
Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more
As Donald J. Trump prepares to begin his second presidential administration on January 20, 2025, many Department of Justice (“DOJ”) priorities and policies are likely to change. One new Biden administration initiative that is...more
1/13/2025
/ Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
When President-Elect Donald J. Trump takes office on January 20, 2025, the U.S. Department of Justice (“DOJ” or the “Department”) is certain to be at the center of the action and conversation in Washington, D.C.—just as it...more
11/20/2024
/ Biden Administration ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Governance Standards ,
Government Agencies ,
Immigration Procedures ,
National Security ,
Trump Administration ,
Unlawful Entry ,
White Collar Crimes
On October 7, 2024, the U.S. Supreme Court declined to hear a case concerning the “willfulness” element of the Anti-Kickback Statute (the “AKS”). This decision leaves intact a recent Second Circuit holding, which established...more
10/11/2024
/ Anti-Kickback Statute ,
Bribery ,
Corruption ,
Denial of Certiorari ,
False Claims Act (FCA) ,
Federal Contractors ,
Healthcare Fraud ,
Illegal Gratuities ,
Incentives ,
SCOTUS ,
Whistleblowers ,
White Collar Crimes
The Department of Justice is stepping up its focus on artificial intelligence (“AI”), with officials warning that harsher penalties could be in store for those who deliberately misuse the technology to commit white collar...more
On October 12, 2022, the U.S. District Court for the District of Columbia dismissed the civil Foreign Agents Registration Act (“FARA”) enforcement action against casino developer and former Republican National Committee...more
In announcing recent changes to its corporate criminal enforcement policies, the Department of Justice (“DOJ” or the “Department”) continued its forceful “tough on crime” initiatives to deter wrongdoing....more
9/27/2022
/ Clawbacks ,
Compliance ,
Corporate Governance ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Investigations ,
Non-Prosecution Agreements ,
Recidivism ,
Self-Reporting ,
Transparency
On June 7, 2022, the media published a search warrant application seeking access to the electronic communications of a retired four-star Marine Corps general, General John R. Allen, in a criminal investigation into potential...more
6/29/2022
/ Campaign Contributions ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Agents ,
Foreign Agents Registration Act (FARA) ,
Foreign Governments ,
Grand Juries ,
Lobbying ,
Political Campaigns ,
Registration Requirement ,
Subpoenas ,
Tax Evasion ,
United Arab Emirates (UAE)
With the holiday season upon us, companies waiting for a nice surprise this Christmas are more likely to find a lump of coal in their stocking. In a series of recent announcements, Department of Justice (“DOJ”) officials have...more
On September 13, 2021, the Department of Justice (“DOJ”) intervened in a False Claims Act (“FCA”) suit alleging that a health insurer defrauded the government by submitting false patient data to wrongfully inflate payments...more
On June 24, 2021, UK law enforcement seized a record-setting £114 million (nearly $160 million) in cryptocurrency as part of an ongoing money laundering investigation. Representing the largest cryptocurrency seizure in UK...more
On March 26, 2021, the Department of Justice (“DOJ”) issued a press release trumpeting the agency’s “historic level of enforcement action” in response to COVID-19 related fraud. Roughly one year after Congress passed the $2.2...more
On January 13, 2021, the Environmental Protection Agency (“the EPA”) announced its enforcement results for fiscal year (“FY”) 2020. The results show that the EPA had a steady year for civil enforcement resolutions and opened...more
On December 1, 2020, Singaporean shipping company Pacific Carriers Limited (“PCL”) entered a $12 million plea agreement to resolve criminal charges that it knowingly failed to record illegal discharges of oil waste and...more
On Sunday, September 6, 2020, the Washington Post reported that U.S. Postmaster General Louis DeJoy’s former North Carolina–based company allegedly used company funds to reimburse employees for donations to federal and state...more
On September 6, 2020, news broke that U.S. Postmaster General Louis DeJoy’s former company allegedly reimbursed its employees with corporate funds for donations that he asked them to make to federal and state political...more
Mere months after Airbus entered into a record-breaking, nearly $4 billion resolution with the U.S., U.K., and France to settle foreign bribery allegations, the U.K.’s Serious Fraud Office (“SFO”) moved on July 30, 2020, to...more
On June 25, 2020, Novartis AG, a Swiss multinational pharmaceutical company, and two subsidiaries reached a combined $345 million resolution with the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange...more
7/16/2020
/ Bribery ,
Cease and Desist Orders ,
Corporate Counsel ,
Department of Justice (DOJ) ,
DPA ,
Foreign Corrupt Practices Act (FCPA) ,
Health Care Providers ,
Novartis ,
Pharmaceutical Industry ,
Popular ,
Securities and Exchange Commission (SEC) ,
Vietnam
The coronavirus pandemic continues to upend the global economy and is increasing compliance risks for businesses in the process. We have previously reported how COVID-19 is increasing risks relating to insider trading and...more
On April 14, 2020, for the first time, the Department of Justice (“DOJ”) published a list identifying all corporate monitors actively engaged by companies as a part of criminal resolutions with the Criminal Division’s Fraud...more