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Back from the Dead? Takeaways from US DOJ’s New Guidelines for FCPA Investigations and Enforcement

On June 9, 2025, the Deputy Attorney General of the United States Department of Justice issued “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (the “Memorandum”). The Memorandum...more

When is “Misleading” Not “False”? The Supreme Court's Decision in Thompson v. United States and Its Implications for Government...

On March 21, 2025, a unanimous Supreme Court held in Thompson v. United States that a federal statute prohibiting “false” statements to banks, 18 USC § 1014, does not apply to statements that are merely misleading. Although...more

Early Signals Show Potentially Increased False Claims Act Enforcement by the Trump Administration on Trade and DEI Matters

The Trump administration’s focus on reducing government spending, its policies on trade and tariffs, and its focus on paring back diversity, equity, and inclusion (“DEI”) mandates may result in an increase in private suits,...more

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