In February, the White House issued an Executive Order "pausing" Foreign Corrupt Practices Act (FCPA) enforcement for 180 days, to "further American economic and national security."1 On June 9, Deputy Attorney General Todd...more
6/24/2025
/ Attorney General ,
Bribery ,
Cartels ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Regulatory Reform ,
Significant Transnational Criminal Organization ,
Voluntary Disclosure ,
White Collar Crimes
The increase in tariffs and export control actions by the Trump Administration has led to additional reporting and compliance obligations for companies that import and export goods. To ensure these new tariffs and rules are...more
In our prior client alert, we examined the growing risk that the Department of Justice (DOJ) would deploy the False Claims Act (FCA) to pursue entities that receive federal funds and operate Diversity, Equity and Inclusion...more
The U.S. Department of Justice (DOJ) announced on May 12, 2025, a strategy shift in its approach to white collar enforcement, identifying specific high-impact areas of focus; an expansion of whistleblower and self-disclosure...more
5/19/2025
/ Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Priorities ,
Fraud ,
National Security ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
On April 2, 2025, the U.S. Department of Justice (DOJ) moved to dismiss the Foreign Corrupt Practices Act (FCPA) case against former Cognizant Technology Solutions Corp. executives Gordon Coburn and Steven Schwartz, United...more
Key Takeaways - The First Circuit ruled in United States v. Regeneron Pharmaceuticals, Inc., that the government must prove but-for causation to establish False Claims Act (FCA) liability based on violations of the...more
2/21/2025
/ Anti-Kickback Statute ,
Compliance ,
Department of Health and Human Services (HHS) ,
False Claims Act (FCA) ,
Healthcare Fraud ,
Life Sciences ,
Medicare ,
Pharmaceutical Industry ,
Risk Management ,
Safe Harbors ,
Whistleblowers
In our prior Baker Donelson Client Alert, we examined the labor and employment implications of Attorney General Pam Bondi's Ending Illegal DEI and DEIA Discrimination & Preferences memorandum. This alert focuses on the...more
The D.C. Council passed emergency legislation on January 9, 2024, in furtherance of its effort to close the D.C. cannabis industry's "gray market." The "gray market" is the cannabis industry that was created when D.C....more
Is subjective intent relevant to FCA claims? The Court answered yes, holding that FCA liability turns on what the defendant actually believed, not on what an objectively reasonable person may have believed. On June 1, 2023,...more
On March 3, 2023, Assistant Attorney General Kenneth Polite delivered the keynote speech at the 38th Annual National Institute on White Collar Crime of the American Bar Association (ABA) in Miami, Florida. AAG Polite's speech...more