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Deputy Attorney General Issues FCPA Guidelines Resuming Limited Enforcement

Key Points - - The U.S. Department of Justice (DOJ) will resume investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA), prioritizing, in part, FCPA actions involving cartels and transnational...more

DOJ White Collar Enforcement Plan Continues To Present Risks for Non-US Companies

Matthew Galeotti’s recent memorandum as head of the Department of Justice’s (DOJ’s) Criminal Division echoes the Trump administration’s “America First” priorities. It directs the Criminal Division to “strike an appropriate...more

Core False Claims Act Theories Top the List of DOJ Criminal Enforcement Priorities

The May 12, 2025, memo from the head of the Department of Justice’s (DOJ’s) Criminal Division highlights 10 “high-impact” areas as the focus of DOJ’s criminal enforcement efforts. (See our May 14, 2025, client alert “In a New...more

In a New Memo, DOJ Outlines White Collar Crime Focus Areas and Prosecutorial Guidance

Key Points - - A new memo suggests DOJ will continue to prosecute white collar fraud and crimes. - DOJ identified 10 “high-impact” areas of focus, prioritizing crimes that cause harm to government programs, citizens, and...more

First Circuit Demands ‘But For’ Causation Between Alleged Kickback and Claim Submission

On February 18, 2025, a panel of the U.S. Court of Appeals for the First Circuit unanimously decided that in order to transform an Anti-Kickback Statute (AKS) violation into a false or fraudulent claim for purposes of False...more

Anti-Bribery and Corruption Risks Remain Despite FCPA Enforcement Pause

On February 10, 2025, President Donald Trump signed an executive order directing the U.S. attorney general, Pam Bondi, to pause Foreign Corrupt Practices Act (FCPA) actions for 180 days until she issues revised FCPA...more

DOJ Enters First Intervention in Cybersecurity Qui Tam

The U.S. government’s recent complaint in a relator-filed case under the False Claims Act (FCA): - Marks the first FCA suit in which the Department of Justice (DOJ) has intervened since launching its ongoing Civil...more

Contractors Settle Cyber Fraud Claims Alleging Ignored Security Measures

Two recent settlements under the False Claims Act (FCA): - Signal enhanced risk around cybersecurity for recipients of federal funds. - Underscore the need to assess compliance with cybersecurity requirements and...more

The Nucleus: Life Sciences Enforcement and Regulatory Updates - March 2024

Circuit Split Widens Over AKS-Based FCA Causation Element - The Anti-Kickback Statute (AKS) continues to form the basis of hundreds of millions of dollars of annual recoveries for the government under the federal False...more

The Nucleus: Life Sciences Enforcement and Regulatory Updates

In this issue of our newsletter on developments impacting the life sciences industry, we examine topics including how the increased DOJ and FDA focus on cybersecurity issues could lead to new theories of False Claims Act...more

The Nucleus: Life Sciences Regulation and Enforcement Updates

We are pleased to present the first issue of our newsletter analyzing recent trends and developments impacting the life sciences industry, including DOJ policy updates and key provisions of the Food and Drug Omnibus Reform...more

DOJ Implements Voluntary Self-Disclosure Policy for US Attorneys’ Offices

On February 22, 2023, the Department of Justice (DOJ) adopted a new policy that establishes a national standard for voluntary self-disclosure credit in corporate criminal enforcement actions brought by U.S. Attorneys’ Offices...more

DOJ Doubles Down on Efforts To Incentivize Early Self-Reporting and Cooperation

On January 17, 2023, the U.S. Department of Justice (DOJ) announced revisions to the Criminal Division’s Corporate Enforcement Policy. The revisions follow Deputy Attorney General (DAG) Lisa Monaco’s September 2022...more

Revisions to the DOJ’s Corporate Criminal Enforcement Policy Will Require Companies To Reevaluate Their Compliance Systems

In a recently published memorandum, Deputy Attorney General (DAG) Lisa Monaco announced important updates to the U.S. Department of Justice’s (DOJ’s) approach to investigating and prosecuting corporate crimes. In the...more

Inside the Courts – An Update From Skadden Securities Litigators

This quarter’s issue includes summaries and associated court opinions of selected cases principally decided between July and October 2020. Class Certification - Cryptocurrency – Definition of a Security - Derivative...more

Insights Conversations: DOJ Enforcement Priorities

Former U.S. attorney Jessie K. Liu recently joined Skadden from her role overseeing the U.S. Attorney’s Office in Washington, D.C., which is not only the largest in the country but also home to one of the busiest Civil...more

DOJ and SEC Issue Second Edition of the FCPA Resource Guide

On July 3, 2020, the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC) jointly released the second edition of the “Resource Guide to the U.S. Foreign Corrupt Practices Act,” which was...more

DOJ’s ‘China Initiative’ Uses Scheme-to-Defraud Charges for Nondisclosure of Ties to China

Although U.S.-China bilateral tensions eased to a degree earlier this year with the signing of an interim trade agreement, fundamental differences remained. These differences — such as the role that China’s industrial policy...more

Cross-Border Investigations Update - September 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more

Skadden's 2019 Insights: Compliance Investigations in China Take On New Urgency

The ongoing trade tensions between the U.S. and China have caused some U.S. companies to become increasingly concerned that the Chinese authorities may subject their local operations to closer scrutiny, leading these...more

DOJ Announces Revisions to Yates Memorandum Policy

On November 29, 2018, in a speech at the 35th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced the Department of Justice’s (DOJ or the Department) revised...more

DOJ Announces ‘China Initiative’ to Investigate and Prosecute Chinese Companies

On November 1, 2018, then-Attorney General Jeff Sessions announced the U.S. Department of Justice’s (DOJ) “China Initiative” with the objective of countering perceived national security threats to the United States from...more

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