The Trump administration has made clear its intent to increase Immigration and Customs Enforcement efforts in order to carry out mass deportations. The agency intends to employ a range of tactics, including those often...more
2/13/2025
/ Department of Homeland Security (DHS) ,
Employer Liability Issues ,
Employer Responsibilities ,
Employment Litigation ,
Enforcement ,
Form I-9 ,
Immigration and Customs Enforcement (ICE) ,
Immigration Procedures ,
Legislative Agendas ,
Regulatory Agenda ,
Trump Administration ,
Warrants
Bradley’s Government Enforcement and Investigations Practice Group is pleased to present the False Claims Act: 2024 Year in Review, our annual review of significant False Claims Act (FCA) cases, developments and trends....more
2/5/2025
/ Anti-Kickback Statute ,
Cybersecurity ,
Damages ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
First-to-File ,
Fraud ,
Fraudulent Inducement ,
Health Care Providers ,
Healthcare ,
Healthcare Fraud ,
Hospitals ,
Materiality ,
Medicare ,
Penalties ,
Public Disclosure Bar ,
Retaliation ,
Reverse False Claims ,
Settlement ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers
With each new presidential administration, prognosticators attempt to forecast coming enforcement priorities. President-elect Donald Trump’s return to the White House is no exception, and theories abound regarding the manner...more
12/12/2024
/ Compliance ,
Department of Homeland Security (DHS) ,
Employees ,
Employer Liability Issues ,
Enforcement Actions ,
Immigration and Customs Enforcement (ICE) ,
Immigration Enforcement ,
Immigration Procedures ,
Immigration Reform and Control Act (IRCA) ,
Legislative Agendas ,
Regulatory Agenda ,
Trump Administration ,
Undocumented Immigrants ,
USCIS
Mandatory disclosure obligations significantly changed for federal grant recipients, sub-recipients, and applicants on October 1, 2024. The amended federal regulation establishing these mandatory disclosures (2 C.F.R. §...more
The phrase “no good deed goes unpunished” represents the figurative irony that results when one seeking to help gets penalized instead. United States v. Moore, a recent decision from the 11th Circuit Court of Appeals,...more
Companies who submit healthcare claims to private payors, provide financial services to customers, interact with domestic or foreign public officials, or otherwise operate in highly regulated industries should take note that...more
8/13/2024
/ Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
New Regulations ,
Pilot Programs ,
Regulatory Requirements ,
Self-Reporting ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
The U.S. Sentencing Guidelines play an enormous role in federal sentencing. While courts are not required to follow the guidelines, the guidelines remain the starting point for determining a defendant’s ultimate sentence. For...more
At last week’s sentencing of Binance CEO Changpeng Zhao, the government recommended a 36-month prison sentence. Despite the serious nature of Zhao’s crimes – failing to maintain an effective anti-money laundering program,...more
On April 15, the U.S. Department of Justice released The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the “Pilot”) designed to encourage individuals to report certain types of criminal...more
4/18/2024
/ Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Non-Prosecution Agreements ,
Self-Disclosure Requirements ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On April 15, the U.S. Department of Justice released The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the Pilot) designed to encourage individuals to report certain types of criminal...more
4/18/2024
/ Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Non-Prosecution Agreements ,
Self-Disclosure Requirements ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
In its traditional form, the advice of counsel defense can validate conduct that might otherwise be considered criminal. But invocation carries a steep cost: The defendant must waive his privilege with the lawyer who gave the...more
New Jersey Sen. Robert Menendez (D), his wife, Nadine, and two businessmen are scheduled to face trial on bribery charges on May 6. They’ll become the latest example where the dual intent, or mixed motive, concept turns the...more
Last month, special counsel Robert Hur issued a report detailing his reasons for declining to charge President Joe Biden for retaining classified documents from Biden's time as vice president. Regardless of one's views on its...more
As we do every year, this issue revisits the key cases and other developments from the year gone by. And by most metrics, 2023 was a notable year for the False Claims Act (FCA).
We start with the numbers: The Department...more
2/28/2024
/ Causation ,
Damages ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Kickbacks ,
Materiality ,
Objective Falsity ,
Penalties ,
Qui Tam ,
Relators ,
Retaliation ,
Scienter ,
Settlement ,
Sovereign Immunity ,
Whistleblowers
When the Corporate Transparency Act took effect earlier this month, most commentary rightly focused on the obligations it imposed and the measures necessary to comply with its terms. As part of that analysis, commentators...more