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Focus, Fairness, & Efficiency: DOJ White Collar Policy Shifts Signal Recalibration, But Not Revolution in Enforcement

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (“DOJ” or the “Department”) issued a series of significant policy changes outlining the Trump administration’s new approach to white-collar enforcement....more

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

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

Supreme Court Declines to Revisit Limitations on Anti-Kickback Statute: What This Means for Enforcement of Corruption, Kickbacks...

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

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

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