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New DOJ Guidelines Mark the End of the FCPA Enforcement “Pause”

On June 9, 2025, Department of Justice (“DOJ”) Deputy Attorney General Todd Blanche issued the highly anticipated “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (the “Guidelines”),...more

Department of Justice Launches “Civil Rights Fraud Initiative” to Target DEI Through False Claims Act

On Monday, May 19, 2025, Department of Justice (“DOJ”) Deputy Attorney General Todd Blanche issued a memorandum establishing the “Civil Rights Fraud Initiative” (the “Memorandum”), in the latest signal that DOJ intends to...more

DOJ’s Criminal Division Turns a “New Page” on White Collar & Corporate Enforcement and Announces Changes in Self-Reporting,...

The Criminal Division at the Department of Justice (“DOJ”) has announced that it is “turning a new page” on white-collar and corporate enforcement with an increased focus on “fairness” and “efficiency.”...more

EEOC and DOJ Issue Joint Press Release and Technical Assistance Documents on “Unlawful DEI-Related Discrimination”

On March 19, 2025, the U.S. Equal Employment Opportunity Commission (“EEOC”) and the U.S. Department of Justice (“DOJ”) issued a joint press release announcing the release of two technical assistance documents designed to...more

Should Your Company Shut Down Its Anti-Corruption Compliance Program and Start Paying Bribes? Here Are a Few Reasons to Think...

On February 10, 2025, President Trump issued a new Executive Order (“EO”) titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” This EO comes on the tail of Attorney...more

DOJ Updates the Evaluation of Corporate Compliance Program Memorandum, Emphasizing Emerging Technologies, Data Analytics, and...

On September 23, 2024, the U.S. Department of Justice (“DOJ”) released updates to its Evaluation of Corporate Compliance Programs policy (the “Updated ECCP”), building upon the March 2023 updates. Since 2017, DOJ has offered...more

DOJ Announces First-In-The-Nation False Claims Act Settlement with PPP Lender

​​​​​​​The government has been actively investigating and prosecuting Paycheck Protection Program (“PPP” or the “Program”) fraud ever since the Small Business Administration (“SBA”) rolled out the Program in the Spring of...more

UPDATE: Trial Court Overturns Former Alstom Executive’s Foreign Corrupt Practices Act Convictions

Former Alstom SA executive Lawrence Hoskins’s jury convictions under the Foreign Corrupt Practices Act (“FCPA”) were set aside on February 26, 2020, by Judge Janet Bond Arterton of the United States District Court for the...more

Former Alstom Executive Convicted of Foreign Corrupt Practices Act Charges on Agency Theory

Lawrence Hoskins, a British citizen and former employee of French conglomerate Alstom SA, has been found guilty by a federal jury in Connecticut of 11 of 12 criminal charges, including six counts of violating the United...more

Two Recent Justice Department Memoranda May Have Significant Consequences for Pending and Future False Claims Act Enforcement

In recent weeks, the United States Department of Justice (“DOJ”) issued two memoranda that might change the calculus of False Claims Act (“FCA”) cases. The memoranda at a minimum provide organizations with new—or at least...more

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