On June 9, 2025, Deputy Attorney General Todd Blanche announced that the U.S. Department of Justice (“DOJ” or the “Department”) will resume investigating and prosecuting violations of the U.S. Foreign Corrupt Practices Act...more
On May 12, 2025, the Criminal Division of the U.S. Department of Justice (“DOJ” or the “Department”) issued a series of significant policy changes outlining the Trump administration’s new approach to white-collar enforcement....more
As Donald J. Trump prepares to begin his second presidential administration on January 20, 2025, many Department of Justice (“DOJ”) priorities and policies are likely to change. One new Biden administration initiative that is...more
1/13/2025
/ Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
When President-Elect Donald J. Trump takes office on January 20, 2025, the U.S. Department of Justice (“DOJ” or the “Department”) is certain to be at the center of the action and conversation in Washington, D.C.—just as it...more
11/20/2024
/ Biden Administration ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Governance Standards ,
Government Agencies ,
Immigration Procedures ,
National Security ,
Trump Administration ,
Unlawful Entry ,
White Collar Crimes
On October 7, 2024, the U.S. Supreme Court declined to hear a case concerning the “willfulness” element of the Anti-Kickback Statute (the “AKS”). This decision leaves intact a recent Second Circuit holding, which established...more
10/11/2024
/ Anti-Kickback Statute ,
Bribery ,
Corruption ,
Denial of Certiorari ,
False Claims Act (FCA) ,
Federal Contractors ,
Healthcare Fraud ,
Illegal Gratuities ,
Incentives ,
SCOTUS ,
Whistleblowers ,
White Collar Crimes
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
It is one of the hardest questions a company can face: after discovering criminal conduct inside your company, do you self-report to the government or not? The reality is that when faced with the question of self-reporting,...more
It is one of the hardest questions a company can face: after discovering criminal conduct inside your company, do you self-report to the government or not? If you can quickly and quietly fix the problem, then you may be able...more
10/13/2023
/ Corporate Misconduct ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Disgorgement ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
Internal Investigations ,
Safe Harbors ,
Self-Reporting ,
White Collar Crimes
Enforcement of corporate crimes, which languished for two years during the COVID-19 pandemic, will grow more vigorous this year and may be accompanied by significantly tougher penalties, partners with Vinson & Elkins’ (“V&E”)...more
5/27/2022
/ Anti-Corruption ,
Bribery ,
Coronavirus/COVID-19 ,
Cryptocurrency ,
Cyber Crimes ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FBI ,
Foreign Corrupt Practices Act (FCPA) ,
Ransomware ,
Securities and Exchange Commission (SEC) ,
Special Purpose Acquisition Companies (SPACs) ,
White Collar Crimes
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
A new sheriff is in town — and that means the potential for big changes ahead for white-collar criminal enforcement in terms of specific areas of focus and volume of investigations...more
6/25/2021
/ Attorney General ,
Biden Administration ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Environmental Justice ,
Federal Trade Commission (FTC) ,
Foreign Corrupt Practices Act (FCPA) ,
No-Poaching ,
White Collar Crimes
As the Biden Administration gains its footing and key positions begin to be filled in the government, there promises to be a significant uptick in enforcement, especially in the areas of antitrust and white collar crime. In...more
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
The COVID-19 pandemic has caused enormous pain and financial harm and it will take months, or even years, before we know its full impact. As of the time that this article is published, there will be over 1.4 million known...more
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
2/1/2020
/ Compliance ,
Corporate Investigations ,
Corporate Misconduct ,
Criminal Investigations ,
Deferred Prosecution Agreements ,
Federal Prosecutors ,
Financial Crimes ,
New Guidance ,
Prosecutorial Discretion ,
Sentencing Factors ,
Serious Fraud Office (SFO) ,
SFO Operational Handbook ,
UK ,
UK Bribery Act ,
White Collar Crimes