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DOJ Formalizes Plan to Use False Claims Act to Enforce “Civil Rights Fraud”

Key Takeaways: - The U.S. Department of Justice (“DOJ”) announced the creation of a new initiative focused on using the False Claims Act (“FCA”) to pursue “Civil Rights Fraud.” - DOJ warned FCA claims could arise when a...more

Will State AGs Fill the Gap in FCPA Enforcement?

Since the start of President Trump’s second administration, some State Attorneys General (AGs) have actively responded to executive orders and policy directives, including by initiating legal challenges in federal courts. Now...more

False Claim Act Liability Under Anti-Kickback Statute Requires But-For Causation: First Circuit Narrows Liability in Growing...

On February 18, 2025, the First Circuit Court of Appeals issued its decision in U.S. v. Regeneron Pharmaceuticals, ruling that the Anti-Kickback Statute (“AKS”) requires the government to prove that an AKS violation was the...more

Trump Administration Pauses FCPA Enforcement – Why Compliance Is Still Critical

On February 10, 2025, President Trump issued an executive order (EO) directing Attorney General Pam Bondi to effectively pause the Justice Department’s enforcement of the Foreign Corrupt Practices Act (FCPA). This was the...more

AG Bondi Overhauls FCPA Enforcement in Day 1 Memo

On February 5, 2025, on her first day in office, U.S. Attorney General Pam Bondi issued fourteen memos outlining new policies for the U.S. Department of Justice (“DOJ”) in a broad range of enforcement arenas. Among these Day...more

Anticorruption and FCPA Enforcement: Takeaways and Lessons Heading into 2025

This is the second in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

Foley Hoag 2024 White Collar Year In Preview Series

The government had another busy year in 2023, investigating and prosecuting healthcare fraud cases on multiple fronts. Contending with the enormous healthcare crises of the now-concluded COVID-19 pandemic and the ongoing...more

Anticorruption Enforcement and the Foreign Corrupt Practices Act: Trends to Track in 2024

This is the seventh in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

Criminal Tax Enforcement – What to Look For in 2024

IRS enforcement activity remained strong in 2023, with the volume of investigations and prosecutions initiated holding steady from 2022. Despite the substantial funding boost provided by the Inflation Reduction Act, with some...more

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