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DOJ and HHS Launch Joint False Claims Act Working Group: Heightened Enforcement Risk Ahead for Healthcare and Government-Funded...

The U.S. Department of Justice (DOJ) and the U.S. Department of Health and Human Services (HHS) have formed a new False Claims Act (FCA) Working Group, according to a joint announcement issued by DOJ on July 2, 2025....more

Paycheck Protection Program (“PPP”) Loan Fraud: A Survey & Analysis of Recent Civil & Criminal Enforcement Outcomes

The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a federal law enacted in or around March 2020 designed to provide emergency financial assistance to the millions of Americans who were suffering the...more

Fraud by Omission? How Thompson v. United States Could Narrow the Reach of the Federal Wire, Mail, and Bank Fraud Statutes

The vast majority of federal white-collar fraud enforcement actions are prosecuted under the wire, mail, or bank fraud statutes.  18 U.S.C. §§ 1341, 1343, and 1344. The Supreme Court’s recent decision in Thompson v. United...more

A Survey of Recent Enforcement Actions, Trends & Priorities

The landscape of criminal prosecution of foreign bribery has shifted, and the second Trump administration has made its priorities clear; however, companies still have 950 million reasons and counting to strengthen their...more

DOJ Adds AI Considerations to Its Evaluation of Corporate Compliance Programs

Last month, the U.S. Department of Justice’s (“DOJ”) Criminal Division announced its periodical update to its Evaluation of Corporate Compliance Programs (“ECCP”), zeroing in on how companies manage risk related to artificial...more

White Collar Quarterly Report - August 2024

In 2023, the number of federal corporate prosecutions remained far below the 25-year average after two consecutive years of increases. ..The DOJ’s Fraud Section secured just $690 million in penalties across eight...more

Engaging in Activities that Violate Federal Law? DOJ Scrutiny of PPP Loan Recipients Turns to Ancillary Companies Supporting the...

Since its inception, the cannabis industry has always existed alongside significant regulatory and compliance challenges. These largely stem from the fact that the manufacture, distribution and possession of marijuana remains...more

“Tip” Away?! SCOTUS Rules That 18 U.S.C. § 666 Does Not Criminalize Gratuities

On Wednesday, June 26, 2024, the Supreme Court ruled that the federal anti-bribery statute does not make it a crime for state and local officials to accept a gratuity for acts taken in the past....more

White Collar Quarterly Report | Q1 2024

We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more

Supreme Court to Weigh in on Scope of Federal Bribery Statute

In Snyder v. United States, the Supreme Court of the United States could redefine the legal boundaries regarding federal bribery as it prepares to answer whether the primary federal bribery statute, 18 U.S.C. § 666,...more

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