Government procurement fraud is pervasive. The vast majority of government procurement fraud goes undetected, and federal agencies rely heavily on whistleblowers to help them determine when scrutiny is warranted. Blowing the...more
At this mid-point of 2023, and now several months on from the ABA’s Spring Antitrust conference, there have been several notable developments concerning cartel enforcement, as new leadership settles in at the U.S. Department...more
US Supreme Court Requests Solicitor General’s Views in FCA Rule 9(b) Context - On May 16, 2022, the US Supreme Court requested a brief from the US Solicitor General on the level particularly required by Federal Rule of...more
The recent Criminal Antitrust Anti-Retaliation Act (CAARA), to be enforced by the Occupational Safety and Health Administration (“OSHA”), offers protection from retaliation for antitrust whistleblowers who come forward to...more
At this point, most employers probably know that the Occupational Safety and Health Administration (“OSHA”) is charged with investigating far more than workplace safety. Indeed, OSHA has a robust Whistleblower Protection...more
No matter how novel a scheme about “coordinating” with competitors to instill “discipline” in the market may seem, odds are that the antitrust enforcers have seen it before and eventually will prosecute it. Take the recent...more
Below, we summarize significant cartel enforcement developments from U.S. and other antitrust enforcers in recent months, including the significant change to longstanding policy by the Department of Justice (DOJ) Antitrust...more
The Commission recently filed an amicus brief defending its Dodd-Frank whistleblower rules. Those rules specify that the anti-retaliation provisions of those amendments to the Exchange Act protect those who chose not to...more
In This Issue: - SEC’s Dodd-Frank Whistleblower Program Report shows best practices make for an effective compliance and ethics program - In unprecedented move, government seeks to extend the responsible...more