The “One Big Beautiful Bill Act,” signed into law by President Trump on July 4, 2025, will fund government efforts to continue to vigorously enforce the immigration laws. Companies in the manufacturing, health care,...more
7/24/2025
/ Construction Industry ,
Employer Liability Issues ,
Enforcement Actions ,
Federal Funding ,
Immigration and Customs Enforcement (ICE) ,
Immigration Enforcement ,
Legislative Agendas ,
Manufacturing Employers ,
New Legislation ,
Popular ,
Trump Administration
A recent Ninth Circuit decision underscores why importers should be worried that they will be hit with a large government bill under the False Claims Act (FCA) to pay for newly raised duties imposed on imported products. The...more
7/9/2025
/ Anti-Dumping Duty ,
Appeals ,
China ,
Customs ,
Enforcement Actions ,
False Claims Act (FCA) ,
Imports ,
International Trade ,
Judicial Authority ,
Jurisdiction ,
Penalties ,
Scienter ,
Tariffs
“Worksite enforcement operations are going to massively expand,” according to a June 12, 2025, interview1 with Border Czar Tom Homan.
Commencing on June 8, 2025, the National Guard arrived in Los Angeles and Santa Ana,...more
Last month, the Department of Justice put trade, customs, and tariff fraud squarely in the spotlight. This isn’t just another line item on the compliance checklist, it’s a loud-and-clear signal that import-related enforcement...more
6/10/2025
/ Corporate Counsel ,
Customs ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Fraud ,
Imports ,
Manufacturers ,
Risk Management ,
Supply Chain ,
Tariffs ,
White Collar Crimes
In less than 100 days, the Trump administration has implemented a dizzying array of new tariffs, significantly increasing costs and complexity for U.S. importers. The administration is keenly aware that companies operating in...more
3/26/2025
/ China ,
Criminal Prosecution ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Statements ,
Foreign Trade Regulations ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Regulatory Requirements ,
Risk Management ,
Risk Mitigation ,
Smuggling ,
Tariffs ,
Trump Administration ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes ,
Wire Fraud
Here are our top tips to assist companies and institutions in preparing for visits by immigration officials. The second Trump administration has set robust enforcement of the immigration laws as a top-level priority. On...more
2/13/2025
/ Compliance ,
Corporate Counsel ,
Department of Homeland Security (DHS) ,
Enforcement Actions ,
Executive Orders ,
Immigration and Customs Enforcement (ICE) ,
Immigration Procedures ,
Immigration Reform ,
Policies and Procedures ,
Risk Management ,
Trump Administration ,
USCIS ,
Visas ,
Warrants
On August 1, 2024, the Department of Justice (DOJ) launched its Corporate Whistleblower Awards Pilot Program, first announced earlier this year. Through the pilot program, the DOJ may issue awards to whistleblowers who...more
10/30/2024
/ Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement ,
Federal Pilot Programs ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
The demise of Chevron opens up new potential defenses in False Claims Act (FCA) cases.
On June 28, 2024, the Supreme Court, in Loper Bright Enterprises v. Raimondo, put an end to Chevron deference to agency interpretation...more
The Department of Justice’s (DOJ) annual False Claims Act (FCA) press release revealed that it increased self-initiated investigations for the federal fiscal year ending September 30, 2023, by 1.5 times over the prior year....more
On November 16, 2023, a federal jury in Los Angeles returned guilty verdicts against two corporate executives of a consumer product distributor for conspiracy to defraud the United States by obstructing the lawful functions...more
Eleventh Circuit Adopts “Totality of the Circumstances” Test for Showing Protected Activity Under SOX and Denies Whistleblower Petition for Review -
In Ronnie v. Office Depot, LLC, --- F.4th ----, 2023 WL 6210623 (11th Cir....more
10/25/2023
/ Appeals ,
Civil Monetary Penalty ,
Fraud ,
Internal Controls ,
Investment Adviser ,
Motion to Dismiss ,
Retaliation ,
Sarbanes-Oxley ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Whistleblower Protection Policies ,
Whistleblowers
SCOTUS to Review SOX Retaliation Case Involving Burden of Proof of Retaliatory Intent -
On May 1, 2023, in Murray v. UBS Securities, LLC, No. 22-660, the United States Supreme Court granted former UBS Securities employee...more
The Supreme Court today issued its ruling on one of the most significant False Claims Act (FCA) cases it has considered in the last several years. In the consolidated cases of United States ex rel. Schutte et al. v. SuperValu...more
Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business. Recent developments include:
Third...more
4/21/2023
/ Arbitration ,
CFTC ,
Commodity Exchange Act (CEA) ,
Corporate Counsel ,
Dodd-Frank ,
Employee Misconduct ,
Popular ,
Retaliation ,
Securities and Exchange Commission (SEC) ,
Statute of Limitations ,
Whistleblower Awards ,
Whistleblowers
Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business...more
On August 17, 2022, the Centers for Medicare and Medicaid Services (CMS) issued a bulletin (Bulletin) to states addressing potentially inappropriate cost-based proposals and practices related to governmental ambulance...more
On July 20, 2022, HHS-OIG published a new Special Fraud Alert on arrangements with telemedicine companies, setting forth seven characteristics OIG believes could suggest a given arrangement poses a heighted risk of fraud and...more
Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business. Recent developments include:...more
Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business...more
On March 3, 2022, at the American Bar Association’s National Institute on White Collar Crime, Attorney General Merrick Garland emphasized in a keynote address the Biden Administration’s stated priority to increase corporate...more
On February 1, 2022, the Department of Justice (DOJ) issued its annual release touting its latest accomplishments in the False Claims Act field, advertising another multibillion-dollar year in recoveries; $5.6 billion makes...more
Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business. Recent developments include: ...more
On October 28, 2021, Deputy Attorney General Lisa Monaco announced three changes to the Department of Justice’s (DOJ) approach to corporate criminal enforcement. Monaco announced the changes during the Keynote Address at the...more
Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business...
SEC to Study Amended...more
On July 1, 2021, United States Attorney General Merrick Garland rescinded the Brand Memorandum and the Sessions Memorandum, which directed Department of Justice (DOJ) attorneys to refrain from using agency guidance to bring...more