News & Analysis as of

Voluntary Disclosure Self-Disclosure Requirements False Claims Act (FCA)

Health Care Compliance Association (HCCA)

Private-pay “crime stoppers”: Digesting the Corporate Whistleblower Awards Pilot Program

The U.S. Department of Justice’s (DOJ) Criminal Division launched its Corporate Whistleblower Awards Pilot Program (“Criminal Whistleblower Program”) in August of 2024 to encourage tips for various types of fraud, including...more

Mintz - Health Care Viewpoints

EnforceMintz – DOJ Policy Developments in 2024 Seek to Motivate More Voluntary Self-Disclosures

Over the past two years, the Department of Justice (DOJ or the Department) has actively incentivized companies to voluntarily self-disclose potential civil and criminal violations. For example, in 2023, in the criminal...more

Mintz

The New Private Equity Post-Acquisition Paradigm

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With private equity deals under harsh scrutiny from the Department of Justice, it is critical that sponsors follow appropriately structured pre and post-acquisition best practices to avoid enforcement exposure and best...more

Proskauer Rose LLP

DOJ Triples Down on Incentivizing Disclosures with Launch of Three-Year Corporate Whistleblower Awards Pilot Program

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Corporate Whistleblower Awards Pilot Program (“Pilot Program”), aimed at incentivizing whistleblowers to report potential criminal conduct. The announcement was anticipated, having been previewed in March 2024 by Deputy...more

Gardner Law

DOJ Enforcement Insights: Key Strategies to Mitigate Risks

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The DOJ had a record year, and we reviewed FCA enforcement action trends to identify trends to help you stay informed and proactive in your compliance efforts. This alert summarizes key takeaways from Amanda Johnston’s recent...more

Snell & Wilmer

Department of Justice Announces Groundbreaking Whistleblower Program in its Ongoing Effort to Incentivize Voluntary Self...

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Department of Justice (DOJ) Deputy Attorney General Lisa Monaco announced that the DOJ is adopting a whistleblower incentive program today at the American Bar Association’s 39th National Institute on White Collar Crime. In...more

Bass, Berry & Sims PLC

False Claims Act Settlements to Know from Q1 2024

Bass, Berry & Sims PLC on

Despite the recent downward trend in DOJ healthcare industry settlements, the first quarter of 2024 saw many noteworthy False Claims Act (FCA) and civil healthcare fraud settlements related to alleged kickbacks, medically...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Pilot Program Promises Non-Prosecution Agreements to Individuals Reporting Fraud, Bribery and Other Corporate Crimes

On April 15, 2024, the Department of Justice’s (DOJ’s) Criminal Division unveiled a new Pilot Program on Voluntary Self-Disclosures for Individuals that offers non-prosecution agreements (NPAs) to individuals who voluntarily...more

Goodwin

DOJ Renews Focus on Private Equity Amid Record False Claims Act Enforcement

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2023 was another record year for False Claims Act enforcement. On February 22, 2024, the U.S. Department of Justice (DOJ) announced that the federal government and whistleblowers were party to a record number of FCA...more

Mintz

EnforceMintz — DOJ’s Efforts in 2023 to Incentivize Voluntary Self-Disclosure

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2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more

Troutman Pepper Locke

Recent Fraud Settlements: DOJ Values Voluntary Self-Disclosure and Corporate Cooperation

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The Department of Justice’s (DOJ) conduct since announcing its February 22, 2023, Voluntary Self Disclosure (VSD) policy, demonstrates that the government continues to place a premium on corporate cooperation in both criminal...more

Sheppard Mullin Richter & Hampton LLP

2024 Top-of-Mind Issues for Life Sciences Companies

As we reflect on 2023 and make predictions for 2024, it is remarkable the number of significant events occurring this past year that will be impactful for the activities of the life sciences industry going forward. Although...more

PilieroMazza PLLC

Justice Department Issues New False Claims Act Guidance on Cooperation Credit That May Reduce FCA-Defendant Liability

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Last week, on May 7, 2019, the U.S. Department of Justice (“DOJ”) announced the issuance of formal guidance to clarify the manner in which the DOJ allocates credit to defendants who cooperate with government investigations in...more

Arnall Golden Gregory LLP

DOJ Identifies And Clarifies How To Obtain Credit For Cooperation In False Claims Act Cases

On May 7, 2019, the United States Department of Justice’s Civil Division further clarified the standards and circumstances under which the Department will award credit to defendants who cooperate with the Department during a...more

Faegre Drinker Biddle & Reath LLP

Disclosure, Cooperation and Remedial Action Necessary for Credit in False Claims Act Matters, DOJ Says

Disclosure, cooperation and remedial action are the three ways that entities or individuals can receive cooperation credit from the U.S. Department of Justice (DOJ) in False Claims Act (FCA) matters, according to guidelines...more

Holland & Knight LLP

Post-Script on Cooperation Credit in False Claims Act Cases

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DOJ Releases Guidance on Cooperation Credit in False Claims Act Cases - The U.S. Department of Justice (DOJ) released guidelines for evaluating self-disclosures and awarding cooperation credit in False Claims Act (FCA)...more

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