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Strategy Considerations for Companies Assessing Risks of Fraud Liability for DEI Programs

On May 19, 2025, the US Department of Justice announced the establishment of the Civil Rights Fraud Initiative, which will “utilize the False Claims Act to investigate and, as appropriate, pursue claims against any recipient...more

DOJ Issues Anticipated FCPA Enforcement Guidelines with Focus on US Interests, Individual Accountability

The US Department of Justice has issued new guidance regarding enforcement of the Foreign Corrupt Practices Act (FCPA) in a June 9 memorandum from Deputy Attorney General Todd Blanche. The memorandum formalizes a shift in...more

DOJ Announces Establishment of Civil Rights Fraud Initiative

The US Department of Justice announced the establishment of the Civil Rights Fraud Initiative on May 19, 2025, which will “utilize the False Claims Act to investigate and, as appropriate, pursue claims against any recipient...more

DOJ Announces New Corporate Enforcement Policies

The US Department of Justice on May 12, 2025 announced revisions to the Criminal Division’s “enforcement priorities and policies for prosecuting corporate and white-collar crimes” under the current US administration. The new...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

US Supreme Court to Address Scienter Standard Under False Claims Act

In what could be the most significant development for False Claims Act (FCA) jurisprudence since Universal Health Services v. United States ex rel. Escobar, on January 13, 2023, the US Supreme Court agreed to consider whether...more

DOJ Announces More Than $3 Billion in 2019 FCA Recoveries

The US Department of Justice (DOJ) has announced that fiscal 2019 recoveries from False Claims Act (FCA) settlements and judgments exceeded $3 billion, with healthcare and procurement fraud as the largest areas of recovery....more

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