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Justice Department’s “Civil Rights Fraud Initiative” Increases False Claims Act Risks Related to Alleged Discrimination

On May 19, 2025, Deputy Attorney General Todd Blanche issued a memorandum announcing the creation of the Department of Justice’s (DOJ) Civil Rights Fraud Initiative (the Initiative), which directs DOJ attorneys to utilize the...more

Future of FCPA Enforcement Uncertain (For Now) as New Administration Revamps the Law Enforcement Toolkit

Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more

DOJ Warns Against Unintelligent Use of Artificial Intelligence

The Department of Justice is stepping up its focus on artificial intelligence (“AI”), with officials warning that harsher penalties could be in store for those who deliberately misuse the technology to commit white collar...more

New CFTC Enforcement Policy Increases Penalties to Deter Recidivists

The U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) — the federal agency tasked with regulating the U.S. derivatives markets, which includes futures, swaps and certain kinds of options — has recently taken...more

DOJ Chooses Sticks Over Carrots: Three Reasons Why Changes to DOJ’s Corporate Enforcement Policy May Chill Cooperation by...

In announcing recent changes to its corporate criminal enforcement policies, the Department of Justice (“DOJ” or the “Department”) continued its forceful “tough on crime” initiatives to deter wrongdoing....more

Holiday Jeers: How The Grinch at DOJ May Make It Harder for Companies to Stay on the Nice List This Christmas

With the holiday season upon us, companies waiting for a nice surprise this Christmas are more likely to find a lump of coal in their stocking. In a series of recent announcements, Department of Justice (“DOJ”) officials have...more

Why Voluntary Independent Compliance Monitorships Are Growing in Popularity

When companies get into trouble, it’s common practice for the government to call on independent third parties to help clean up the mess. Companies under investigation by the Department of Justice (“DOJ”) often agree to...more

World Bank’s “Major Initiative” Should Enhance Evaluations Of Corporate Compliance Programs

During a roundtable at the Fifth International Debarment Colloquium last month, Joseph Mauro, a spokesperson for the Compliance Unit of the World Bank Group’s (“World Bank”) Integrity Vice Presidency (“INT”), announced recent...more

Record-Setting $114 Million Whistleblower Award Will Incentivize More Leaks To Law Enforcement

On October 22, 2020, the Securities and Exchange Commission (the “SEC” or “Commission”) announced a $114 million whistleblower award—by far the largest amount ever awarded and more than doubling the previous record of nearly...more

New CFTC Compliance Guidance Echoes Approach By Other Agencies

On September 10, 2020, the Commodity Futures Trading Commission (“CFTC”) Division of Enforcement released its long-awaited “Guidance on Evaluating Compliance Programs in Connection with Enforcement Matters,” which will be...more

DOJ Updates Its Guidance On Corporate Compliance Programs

In a little-noticed move yesterday, the U.S. Department of Justice (“DOJ” or “Department”) quietly amended its most important guidance document on corporate compliance. While the updates are far from a dramatic overhaul, they...more

Little “New” in SFO’s New Guidance on Compliance Programs

On January 17, 2020, the United Kingdom’s Serious Fraud Office (“SFO”) published new guidance regarding how the office assesses the compliance programs of organizations that are under investigation. “Evaluating a Compliance...more

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