On Wednesday, July 2, 2025, the U.S. Department of Justice (DOJ) and the U.S. Department of Health and Human Services (HHS) announced the creation of a DOJ-HHS False Claims Act Working Group. The Working Group is a procedural...more
7/7/2025
/ Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Drug Pricing ,
Enforcement Actions ,
False Claims Act (FCA) ,
Healthcare Fraud ,
Medicaid ,
Medical Devices ,
Medicare ,
Medicare Advantage ,
Trump Administration ,
Working Groups
On Monday, May 19, 2025, the U.S. Department of Justice (DOJ) announced a new initiative titled the Civil Rights Fraud Initiative, which will use the False Claims Act (FCA) to further the Trump Administration’s stated goals...more
As discussed in a recent Cozen O’Connor Alert, Diversity, Equity and Inclusion (DEI) has been at the top of President Trump’s mind, so much so that he recently issued an executive order effectively ending the use of DEI in...more
2/12/2025
/ Affirmative Action ,
Anti-Discrimination Policies ,
Civil Rights Act ,
Compliance ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Employment Discrimination ,
Enforcement Actions ,
Executive Orders ,
False Claims Act (FCA) ,
Federal Contractors ,
Trump Administration
The Department of Justice’s Antitrust Division (Antitrust Division) updated its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations (Antitrust Compliance Guidance) on November 12, 2024. The new...more
11/25/2024
/ Anti-Retaliation Provisions ,
Artificial Intelligence ,
Collaboration ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Electronic Communications ,
Instant Messaging Apps ,
Non-Disclosure Agreement ,
Pricing ,
Software
On November 29, 2023, Department of Justice (DOJ or Department) policymakers announced explicitly that they are, for the first time, leveraging data analytics to help proactively identify and prosecute crimes in foreign...more
11/30/2023
/ Analytics ,
Anti-Corruption ,
Bribery ,
Corporate Counsel ,
Criminal Conspiracy ,
Data Collection ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Investigations ,
Money Laundering ,
OIG ,
Pharmaceutical Industry ,
Price Inflation ,
Self-Disclosure Requirements
In its most recent installment of revamped white-collar criminal enforcement and compliance policies, the Department of Justice (DOJ) unveiled on Wednesday a new “Mergers & Acquisitions Safe Harbor Policy.” Deputy Attorney...more
As part of a sweeping revamp of its white-collar criminal enforcement policies that began last year, the Department of Justice (DOJ) announced two significant changes last week. The first is a new three-year pilot program...more
On January 17, 2023, the Department of Justice (DOJ) rolled out a significant change to its existing Corporate Enforcement Policy (CEP) that will grant as much as a 75% reduction in fines for companies that voluntarily...more
On September 10, 2020, the Commodity Futures Trading Commission (the CFTC) issued a new guidance memorandum outlining factors that the Division of Enforcement (the division) will consider when evaluating compliance programs...more
In July 2020, the Antitrust Division of the U.S. Department of Justice (Antitrust Division) applauded the International Competition Network (ICN) initiative on cross-border leniency cooperation to fight international price...more
Treasury Secretary Steven Mnuchin issued a warning on the heels of the second funding of the federal Payroll Protection Program (PPP) that large or public companies will be audited if they received a loan under the program....more
5/13/2020
/ Audits ,
CARES Act ,
Coronavirus/COVID-19 ,
Eligibility ,
Federal Loans ,
Government Investigations ,
Paycheck Protection Program (PPP) ,
Risk Management ,
SBA Lending Programs ,
Secretary of the Treasury ,
U.S. Treasury
We all know by now we are in the midst of a pandemic. Many businesses are either receiving or giving notice of their inability to satisfy contractual obligations due to the various government orders and shut downs. ...more
On July 11, 2019, the U.S. Department of Justice (DOJ), Antitrust Division (Antitrust Division) announced new guidance concerning the effect of compliance programs in criminal antitrust cartel sentencing that significantly...more
Under new Justice Department guidance, corporate defendants have a crucial, time-sensitive window to implement remedial changes independently to potentially avoid the imposition of a government-required monitor to oversee...more
Recent Congressional legislation provided a procedure for U.S. law enforcement to obtain foreign-located communications data from U.S. service providers, ending a long-running dispute concerning the extraterritorial reach of...more
On February 27, 2018, the Supreme Court heard arguments in In re Warrant to Search a Certain Email Account Controlled & Maintained by Microsoft Corp. (Microsoft). At issue is an unsettled question concerning the territorial...more
On February 9, 2018, funding was restored to the federal government through March 23, 2018. The spending legislation is significant for the cannabis industry for two reasons. First, the budget deal extends the...more
On October 16, 2017, the Supreme Court granted certiorari in In re Warrant to Search a Certain Email Account Controlled & Maintained by Microsoft Corp. (Microsoft). In taking the case for review, the Supreme Court has...more
Seeking to close a perceived “gap” in regulations intended to facilitate the government’s efforts to curb money laundering and the financing of terrorism, the U.S. Department of the Treasury’s Financial Crimes Enforcement...more
9/1/2016
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
Exemptions ,
Financial Institutions ,
FinCEN ,
Patriot Act ,
Proposed Regulation ,
Public Comment ,
Securities and Exchange Commission (SEC) ,
Terrorism Funding
On June 27, 2016, in an 8-0 decision, the U.S. Supreme Court reversed and remanded to the Fourth Circuit the conviction of former Virginia Governor Robert McDonnell on honest services fraud charges and charges that Governor...more