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The End of 180 Days of Uncertainty? DOJ Closes Current FCPA Investigations, Issues New Guidelines for FCPA Enforcement

On June 9, Deputy Attorney General Todd Blanche issued a memorandum (the Memorandum) outlining revised guidelines for investigation and enforcement of the Foreign Corrupt Practices Act (FCPA). The U.S. Department of Justice...more

The Future of the False Claims Act

On May 19, 2025, Deputy Attorney General Todd Blanche issued a memorandum titled Civil Rights Fraud Initiative announcing the Department of Justice’s (DOJ) plan to use the False Claims Act (FCA) to “aggressively” pursue...more

Circuit Split Deepens on Anti-Kickback Statute’s Causation Standard

Introduction: In its recent decision in United States v. Regeneron Pharmaceuticals, Inc., the United States Court of Appeals for the First Circuit deepened an existing federal circuit court split regarding the causation...more

Trump Administration Plans Aggressive FCA Enforcement

At the Federal Bar Association’s annual qui tam conference in Washington, D.C. on Feb. 20, 2025, the Deputy Assistant Attorney General for the Department of Justice’s (DOJ) Commercial Litigation Branch, Michael Granston, said...more

Long Live the FCPA?

The Trump administration has taken significant action this week to overhaul the executive branch’s long-standing policy toward the prosecution of white collar offenses. First, a memo issued by newly confirmed U.S. Attorney...more

In Trump’s Second Term, Healthcare Enforcement May Remain Business as Usual

Compared with other issues, healthcare enforcement during President-elect Donald Trump’s upcoming second term has received little attention. When he takes office again on January 20, should industry actors like pharmaceutical...more

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