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DOJ’s Approach to White Collar Enforcement: Target Those Who Harm U.S. Interests While Minimizing Collateral Damage

The U.S. Department of Justice (DOJ) recently announced Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA). The June 9 memorandum from Deputy Attorney General Todd Blanche instructs...more

DOJ Announces Changes to White Collar Enforcement Policies, Focusing on “Most Egregious” Crimes

This week, the U.S. Department of Justice (DOJ) announced the Criminal Division’s new white collar enforcement plan, changes to its Corporate Whistleblower Pilot Program, and revisions to the Corporate Enforcement and...more

DOJ Announces Larger FCA Recoveries and More Whistleblower Cases Filed in 2024

On January 15, 2025, the U.S. Department of Justice (DOJ) announced $2.9 billion in total False Claims Act (FCA) recoveries for FY 2024, a slight increase from 2023. In addition to growing recoveries, DOJ announced a new...more

DOJ’s Corporate Whistleblower Pilot Program Hits the Ground Running: Is Your Compliance Program Ready?

The U.S Department of Justice’s (DOJ or Department) Corporate Whistleblower Awards Pilot Program (Pilot Program) has hit the ground running, reportedly triggering more than 100 reports since it went live on August 1, 2024....more

SEC Is Looking at Your Vendor Contracts for Whistleblower Restraints – Fines Seven More Companies

The U.S. Securities and Exchange Commission (SEC) recently settled charges against seven companies for violating SEC Rule 21F-17(a), which prohibits conduct that hinders whistleblowing to the SEC. The settlements focus on...more

DOJ’s Much-Anticipated Corporate Whistleblower Awards Pilot Program Is Off to the Races

On August 1, 2024, the U.S. Department of Justice (DOJ) released details about its new Corporate Whistleblower Awards Pilot Program. As previewed by Deputy Attorney General Lisa Monaco in March, individuals (not entities) who...more

Whistleblower Protections: Federal Agencies Ramp Up Enforcement

Federal agencies are continuing to prioritize and ramp up enforcement of whistleblower protection rules, underscoring the need for all companies – both public and private – to undertake routine compliance reviews. On June...more

DOJ to Use ‘Carrots to Wield Larger Sticks’ in 2024

The more things change, the more things stay the same. For years, U.S. Department of Justice (DOJ) leadership has used the ABA National Institute on White Collar Crime and other major conferences to highlight enforcement...more

2021 FCA Recoveries Bounce Back from Decade-Low . . . Maybe

On February 1, the U.S. Department of Justice (DOJ) announced the second-largest annual total recoveries in the history of the False Claims Act (FCA)—$5.6 billion—for FY 2021 (October 2020 – September 2021)...more

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