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Heightened False Claims Act Enforcement Risks Highlight the Importance of Compliance

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

Future of FCPA Enforcement Uncertain (For Now) as New Administration Revamps the Law Enforcement Toolkit

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

Whistleblowers Wanted: Proliferation of DOJ Whistleblower Policies Invites Harmonization by the Trump Administration

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

White Collar and Corporate Criminal Enforcement in the Trump 2.0 Era

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

DOJ Warns Against Unintelligent Use of Artificial Intelligence

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

DOJ Can’t Force Ex Post Facto FARA Registration, Court Says

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

DOJ Chooses Sticks Over Carrots: Three Reasons Why Changes to DOJ’s Corporate Enforcement Policy May Chill Cooperation by...

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

FARA Enforcement Is Here to Stay

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

Holiday Jeers: How The Grinch at DOJ May Make It Harder for Companies to Stay on the Nice List This Christmas

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

DOJ Intervenes in Another Medicare Advantage FCA Suit

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

UK Makes Record-Setting Crypto Seizure In Money Laundering Investigation

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

A Second Wave Of COVID-19 Fraud Enforcement: An Emerging Risk For Businesses

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

EPA Announces Results For FY 2020, Foreshadowing Increased Enforcement Under The Biden EPA

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

Shipping Company Reaches $12 Million Plea Agreement To Resolve Environmental Charges

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

Novartis’ And Alcon’s $345 Million FCPA Case Signals Increased Scrutiny Of Gifts And Entertainment And New Focus On Scientific...

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

Monitoring Corporate Monitors: DOJ Publishes List of Compliance Monitors, Improving Transparency and Accountability in the...

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

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