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U.S. Treasury Department Takes Action Against Russian Darkmarket Entity as Latest Government Move Against Cybercrime

On April 5, the U.S. Treasury Department's Office of Foreign Assets Control (“OFAC”) in the U.S. Department of the Treasury named Genesis Market to OFAC’s Specially Designated Nationals List (“SDN List”). Genesis Market is...more

Department of Justice Announces First-Ever Pilot Program on Compensation Incentives and Clawbacks, Revisions to Corporate Guidance...

On March 2, 2023, in remarks delivered at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy creating incentives for companies to adopt...more

After Nearly Fifty Years of Dormancy, Criminal Monopolization Charges Have Returned

​​​​​​​For nearly 50 years, the Antitrust Division of the United States Department of Justice (DOJ) has brought federal criminal charges only for allegations of illegal coordinated behavior among competitors in violation of...more

DOJ Puts Recipients of Federal Funds on Notice: New “Procurement Collusion Strike Force” to Focus Antitrust Scrutiny on Public...

The Justice Department announced this week the formation of a new Procurement Collusion Strike Force, which will focus on “deterring, detecting, investigating and prosecuting antitrust crimes, such as bid-rigging conspiracies...more

Newly Announced Antitrust Division Policy Rewards Effective Compliance Programs

An effective antitrust compliance program is more valuable than ever, now that the Department of Justice has confirmed that such a program will influence government charging and sentencing decisions. On July 11, 2019,...more

DOJ Issues Consolidated Guidance for False Claims Act Cooperation Credit

The United States Department of Justice this month released a revised and consolidated set of guidelines for determining cooperation credit for organizations facing exposure under the False Claims Act. The consolidated...more

DOJ Levels False Claims Act at Pharmacies to Combat Opioid Crisis

This month the Department of Justice brought a “first of its kind” action against two pharmacies, their owner, and three pharmacists for allegedly dispensing and billing Medicare for prescriptions in violation of both the...more

For FY2018, Justice Department Touts Nearly $3 Billion in False Claims Act Recoveries, Mostly From Qui Tams and Alleged Healthcare...

The Justice Department announced in a recent press release that it obtained more than $2.8 billion in settlements and judgments from cases involving fraud and false claims against the government. The vast majority of this...more

What Does it Mean When the Attorney General Thinks The False Claims Act’s Qui Tam Provision is an “Abomination” and...

President Donald Trump’s nominee for Attorney General, William Barr, is in the news for a June 2018 memo to top Justice Department officials criticizing special counsel Robert Mueller’s obstruction-of-justice investigation. ...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

Federal Civil Penalties Going Up, Way Up

The United States Department of Justice (“DOJ”) published an Interim Final Rule on June 30th nearly doubling the per-claim civil penalties for violations of a number of laws, including the False Claims Act (FCA), the Program...more

Yates Memo in Action: No Cooperation Credit in FCPA Enforcement for Failing to Disclose Key Facts

A recent case illustrates both the ongoing corruption risks for U.S. companies doing business in developing countries such as China and the Government’s tougher stance on settling white collar crime cases. In this case, the...more

DOJ Foreshadows Future Certification Requirement for Businesses to Receive Cooperation Credit

Last fall, Deputy Attorney General Sally Yates announced (Yates memo) that the DOJ would require businesses to share all relevant facts about individuals when disclosing misconduct to be entitled to cooperation credit. The...more

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