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DOJ-HHS Establishes New Working Group to Enhance FCA Enforcement

On July 2, 2025, the U.S. Department of Justice (DOJ) announced the formation of a new working group in collaboration with the U.S. Department of Health and Human Services (HHS) focused on the enforcement of the False Claims...more

Trump Administration's FCPA Investigations and Enforcement Guidelines

On June 9, Deputy Attorney General Todd Blanche released a much-anticipated update to the Trump administration’s plans for enforcement of the Foreign Corrupt Practices Act (FCPA)....more

The False Claims Act Enters the School Zone

On May 19, 2025, the U.S. Department of Justice (DOJ) announced the launch of a Civil Rights Fraud Initiative, which will use the False Claims Act (FCA) as a basis for investigating the diversity, equity, and inclusion (DEI)...more

Trump Pauses FCPA Enforcement: Implications for Corporate Compliance Strategies

On February 10, President Donald J. Trump signed an executive order and accompanying fact sheet directing U.S. Attorney General (AG) Pam Bondi to pause the initiation of new investigations and enforcement actions, and to...more

The Stick and the Carrot: DOJ Continues to Eye Corporate Crimes, While Encouraging Prompt Self-Disclosures of Misconduct...

On October 4, Deputy Attorney General (DAG) Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (M&A). This policy is...more

Does the Government Retain Control of False Claims Act Cases?

United States ex rel. Polansky v. Executive Health Resources, Inc. (S. Ct. June 16, 2023) - The vast majority of False Claims Act cases are initiated by private parties, known as relators, not the government. In fact,...more

Personal Devices and Messaging: Evolving Compliance Concerns and Best Practices [Audio]

With methods of professional communication constantly evolving, the U.S. Department of Justice (DOJ) recently revised its Evaluation of Corporate Compliance Programs to address how prosecutors should evaluate the ways that...more

Conducting Corporate Investigations in an Era of Individual Accountability: New Guidance on Corporate Criminal Enforcement

As recently discussed here, on September 15, Deputy Attorney General Lisa Monaco issued a memorandum outlining further revisions to the Department of Justice's (DOJ) criminal enforcement policies and practices. This latest...more

Record Year for False Claims Act Settlements

In 2021, the Department of Justice (DOJ) obtained more than $5.6 billion in False Claims Act settlements and judgments — the largest amount since 2014 and the second largest amount recorded. This number is inflated by the...more

DOJ Reintroduces Corporate Compliance Monitors

On October 28, Deputy Attorney General Lisa Monaco announced that corporate monitors will once again play a key role in Department of Justice (DOJ) enforcement actions, stating that DOJ is “committed to imposing monitors...more

DOJ and Compliance: Great Expectations and Even Greater Consequences Ahead

As 2020 drew to a close, Indivior PLC, a global pharmaceutical company and manufacturer of the opioid treatment Suboxone, was sentenced in the U.S. District Court for the Western District of Virginia for making false...more

Avoiding “Contextual Compliance” in the Year of COVID and Beyond

Despite 2020 being an unprecedented and challenging year for business, the government has not slowed down its record-breaking enforcement actions. In late October, the U.S. Department of Justice (DOJ) and Securities and...more

Three Takeaways from the Updated DOJ and SEC FCPA Resource Guide

On July 3, 2020, the U.S. Department of Justice and the Securities and Exchange Commission issued a Second Edition of the Resource Guide to the U.S. Foreign Corrupt Practices Act (the Guide), representing the Guide’s first...more

DOJ Amplifies Compliance Guidance, Focusing on Customization, Continuous Improvement, Third-Party Relationships and Resourcing

On June 1, the U.S. Department of Justice updated its guidance on the Evaluation of Corporate Compliance Programs (DOJ Compliance Guidance). While the changes are modest, they reflect DOJ’s evolving expectations regarding...more

Eleventh Circuit Says Difference Of Opinion Does Not Establish Falsity In False Claims Act Case

On September 9, in a setback for AseraCare but an overall win for hospice providers, the Eleventh Circuit affirmed a Northern District of Alabama decision to grant a new trial in a False Claims Act (FCA) case against...more

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