The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
Exploring the AI and Crypto Intersection
The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
INTERPOL and Child Kidnapping Cases. What are INTERPOL’s Abilities and Limitations?
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The CFPB and State AGs Act Jointly Against Online Educational Company
Will the U.S. Have a GDPR? With Rachael Ormiston of Osano
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
The Department of Justice (DOJ) continues to demonstrate its sustained interest in COVID-19 relief fraud as an enforcement priority and we can expect to see persistent enforcement in this area....more
Note: The March 25 version of this article has been updated. The other day, the FTC announced settlements with two different companies that allegedly made false promises to small businesses that their companies could help...more
After dozens of high-profile criminal prosecutions and a growing wave of civil investigations, the Department of Justice’s (“DOJ”) Covid-19 Fraud Enforcement Strike Force is poised to continue its pursuit of fraud, abuse, and...more
The Department of Justice appears to be shifting its focus from investigating fraudulent behavior by Paycheck Protection Program (PPP) borrowers to investigating lenders and related institutions....more
INTRODUCTION - On 24 January 2023, the Board of Governors of the Federal Reserve System (the FRB) announced it entered into a consent order (Consent Order) with a member bank imposing an approximately US$2.3 million civil...more
In May 2022, the US Department of Justice (US DOJ) filed its first civil complaint for Payroll Protection Program (PPP) fraud under the federal False Claims Act (FCA) in a Florida federal court. The government alleged that...more
On December 8, the U.S. Small Business Administration (SBA) issued a statement regarding its intent to investigate certain participants in the Paycheck Protection Program (PPP) created by the Coronavirus Aid, Relief, and...more
On June 3, a federal court filing in the Southern District of Florida by an Atlanta-based FinTech company revealed that the small business lender is under DOJ investigation for alleged PPP loan approval practices. According...more
The Department of Justice (“DOJ”) continues rolling out new settlement agreements related to COVID-19 fraud - highlighting the government’s and a common relator’s efforts to crack down on those alleged to have improperly...more
The Department of Justice (“DOJ”) continues racking up more settlement agreements under the False Claims Act, 31 U.S.C. § 3729 et seq (“FCA”) with companies and individuals alleged to have improperly used funds received...more
The FTC filed suit against California fast food franchisor Burgerim in early February. The case is the FTC’s first major enforcement action against a franchisor in about a decade....more
On February 1, 2022, the U.S. Department of Justice (DOJ) announced that it had recovered more than $5.6 billion in Fiscal Year (FY) 2021 settlements and judgments from civil cases involving fraud and the False Claims Act...more
The trend of private parties suing businesses under the False Claims Act, 31 U.S.C. § 3729 et seq (“FCA”) for violating requirements of the Paycheck Protection Program (“PPP” or the “Program”) continues. Just recently, the...more
With over $2.2 billion in recoveries for the Department of Justice (DOJ) in settlements and judgments from civil cases involving fraud and the False Claims Act (FCA) in 2020, statistics confirm that the FCA remains an...more
In the Spring of 2020, the Small Business Association (“SBA”) began administering the Paycheck Protection Program (the “PPP” or the “Program”) to provide SBA-backed loans to help eligible businesses maintain their workforces...more
The U.S. Securities and Exchange Commission (“SEC”) recently identified cyberthreats as an enforcement priority (see 2021 Examination Priorities). Within months of the Commission’s announcement, the Commission brought three...more
COVID-19 Task Force Established to Enhance Enforcement Efforts against Fraud - On May 17, 2021, the Department of Justice and U.S. Attorney General announced the establishment of the COVID-19 Fraud Enforcement Task Force,...more
As part of its ongoing investigation into the Federal Reserve’s administration of pandemic relief lending programs, House Select Subcommittee on the Coronavirus Crisis Chair James E. Clyburn sent a letter to Fed Chair Jerome...more
In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve), in response to an increased number of inquiries and access requests from companies with fintech and other narrow purpose charters, invited...more
Under President Biden and Attorney General Merrick Garland, the U.S. Department of Justice (DOJ) is expected to focus more intently on white collar enforcement than it did under the Trump administration. Fraud and abuse...more
In this Issue. The federal bank regulatory agencies announced that the temporary change to the supplementary leverage ratio for depository institutions will expire as scheduled on March 31, 2021; the Small Business...more
The Financial Institutions Reform, Recovery and Enforcement Act of 1989 (“FIRREA”) is a powerful tool in the prosecutorial arsenal. Due to its long statute of limitations, expansive penalty provision, and low civil burden of...more
In this Issue. The Consumer Financial Protection Bureau (CFPB) announced the rescission of its 2020 Statement of Policy Regarding Prohibition on Abusive Acts or Practices, possibly signaling an increase in enforcement...more
Yesterday, President Joe Biden signed the $1.9 trillion American Rescue Plan Act of 2021 (Act), which includes new pandemic-relief grants for small and mid-sized restaurants and bars; expansion of the Paycheck Protection...more