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DOJ Announces Over $2.9 Billion in False Claims Act Recoveries in Fiscal Year 2024

In a press release issued on January 15, 2025, the US Department of Justice released its annual statistics and announced that recoveries from False Claims Act settlements and judgments in fiscal year 2024 topped $2.9...more

DOJ Update : Financial Awards for Corporate Whistleblowers, Enhanced Penalties for Fraud Involving AI Misuse

The US Department of Justice (DOJ) continues to enhance its tougher-on-corporate-crime policy stance as first announced by Deputy Attorney General Lisa Monaco in 2021. In remarks on March 7 and March 8, DAG Monaco and Acting...more

False Claims Act Enforcement Continues to Target Education Industry

A recent settlement agreement presents another example of how educational institutions can find themselves facing potential liability under the False Claims Act (FCA). The settlement illustrates how FCA liability remains a...more

Anti-Bribery And Corruption Survey Report

Survey: Tech gaps, third parties pose biggest ABAC threats - Compliance professionals surveyed regarding their anti-bribery and corruption efforts (ABAC) indicated resource support deficiencies in areas including staffing...more

Key Strategies and Considerations for Chinese Companies Preparing for and Responding to a Subpoena

It is the prerogative of government authorities—US and non-US alike—to demand information from individuals or organizations and seek the assistance of courts to enforce compliance. Although such demands take various forms,...more

Tele-Tuesday: DOJ National Healthcare Fraud Takedown Targets Telehealth – But Should DOJ’s Focus Be Elsewhere?

DOJ recently announced a massive coordinated effort with other federal agencies to charge 345 defendants allegedly responsible for over $6 billion in fraud. DOJ, OIG, FBI, DEA, and various US Attorneys’ Offices in 51 federal...more

DOJ and OIG Warn Against Fraud Schemes Related to COVID-19 Pandemic

In managing the quickly evolving healthcare landscape during this current crisis, healthcare companies should be wary of fraudsters who attempt to divert critical resources. ...more

Legalization of Hemp Production – An End-of-Year Present?

On December 20, President Donald Trump signed the Agriculture Improvement Act of 2018 (Farm Bill), which in part removes hemp and hemp-derived products, including cannabinoids, with less than 0.3% tetrahydrocannabinol (THC),...more

DOJ Increases Focus on Individual Accountability in Corporate Wrongdoing

US Deputy Attorney General Rod J. Rosenstein recently announced that in every corporate investigation, the US Department of Justice will make it a top priority to pursue individuals responsible for corporate wrongdoing. This...more

Ninth Circuit Panel: Escobar Test for Implied Certification Liability Is Mandatory

Unless and until the US Court of Appeals for the Ninth Circuit, “en banc, interprets Escobar differently,” a Ninth Circuit panel, relying on past case law, has ruled that relators seeking to establish False Claims Act...more

DOJ Officials Suggest a Broadened Corporate Declination Policy Beyond the FCPA

Recent statements by top US Department of Justice officials indicate that DOJ may consult the FCPA Corporate Enforcement Policy for guidance outside of the Foreign Corrupt Practices Act context in assessing whether a...more

Compliance as a Valuable Tool for Avoiding Enforcement Action in Mexico and Latin America

The Recent Focus on Corruption in Mexico - On July 19, 2017, the General Law of Administrative Responsibilities (GLAR) went into effect in Mexico, making it a “serious administrative offense” for individuals and companies...more

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