News & Analysis as of

Corporate Counsel Fraud

WilmerHale

UK Failure to Prevent Fraud Offence to Come into Force - Is Your Organisation Prepared?

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The new strict liability corporate criminal offence of Failure to Prevent Fraud (FTPF) comes into effect in England and Wales on 1 September 2025. ...more

WilmerHale

DOJ Health Care Fraud Unit Announces First Enforcement Action Under Updated Corporate Enforcement Policy

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The U.S. Department of Justice (“DOJ”) Criminal Division and the U.S. Attorney’s Office for the Western District of North Carolina recently announced the first non-prosecution agreement (“NPA”) coming out of DOJ’s Health Care...more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for July 2025

Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine the following matters: • An SEC complaint alleging a Georgia...more

Husch Blackwell LLP

Mid-Year Update: PPP Investigations Continue as DOJ Enforcement Priority

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As we enter the second half of 2025—over five years now since the COVID-19 pandemic began—federal government scrutiny relating to Paycheck Protection Program (PPP) loans received in the early days of the pandemic is still...more

Husch Blackwell LLP

Precious Metals Fraud Case Invites Challenges to CFTC's Antifraud Authority

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On July 21, 2025, in Commodity Futures Trading Commission et al. v. TMTE Inc et al., a Texas district court denied summary judgment to both the Commodity Futures Trading Commission (CFTC) and two individual defendants in a...more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for June 2025

Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine the following matters: • An SEC settlement with an ex-CEO...more

McDermott Will & Schulte

DOJ complaint underscores Trump administration’s use of the FCA to enforce US trade laws

A recent complaint – U.S. ex rel. Joyce v. Global Office Furniture, LLC, et al. – marks one of the Trump administration’s first publicly filed False Claims Act (FCA) enforcement actions focused on tariff evasion. In its July...more

Baker Botts L.L.P.

Beyond the Fine: What Financial Gatekeepers Must Learn from Interactive Brokers’ OFAC Settlement

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has significantly increased its focus on sanctions compliance for “financial gatekeepers,” including financial institutions and other firms...more

Morrison & Foerster LLP

DOJ Deploys Specialized Criminal Unit to Target Tariff Evaders

The United States Department of Justice (DOJ) has deployed its Market Integrity and Major Frauds Unit to target tariff evasion, a clear sign of the escalation of trade enforcement. The Criminal Division’s specialized unit,...more

Troutman Pepper Locke

DOJ Ramps Up Enforcement Efforts Targeting Tariff Evasion and Trade Fraud

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The U.S. Department of Justice (DOJ) has announced that it is expanding its enforcement priorities to include a focus on import-related fraud — particularly schemes aimed at evading U.S. tariffs and duties. This marks a...more

Clark Hill PLC

Key lessons on the False Claims Act for government contractors after Raytheon’s $8.4 million settlement

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Government contractors should be on high alert following the recent announcement that Raytheon Company, its parent RTX Corporation, and Nightwing Group, LLC, have agreed to pay $8.4 million to resolve allegations of violating...more

Bradley Arant Boult Cummings LLP

SEC Enforcement in the Second Quarter of 2025

In May 2025, we summarized the U.S. Securities and Exchange Commission’s (SEC) Division of Enforcement activity during the first quarter of the new presidential administration. With the second quarter now concluded, and Paul...more

Troutman Pepper Locke

New Wave of Privacy Litigation: Plaintiffs Press Untested Theories Under 2005 Colorado Prevention of Telemarketing Fraud Act

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In what appears to be an emerging privacy litigation trend, plaintiffs’ attorneys have recently filed a series of putative class action lawsuits targeting data companies in possession of cellular telephone numbers. The...more

Mintz

Dodging Duties: The Ninth Circuit Affirms an Expansive Application of the False Claims Act Consistent with Trump Administration...

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On June 23, 2025, the United States Court of Appeals for the Ninth Circuit affirmed a district court judgment in a case in which the jury found the defendant knowingly made false statements on customs forms to avoid paying...more

Bradley Arant Boult Cummings LLP

AI, Deepfakes, and the Rise of the Fake Applicant – What Employers Need to Know

In an age of artificial intelligence and technological advances that improve the quality of deep fake programming, companies must remain vigilant to protect their brand and assets. They also have to be wary of who is applying...more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for May 2025

On May 14, 2025, Deputy Enforcement Director Antonia Apps told those gathered at an anti‑money laundering conference in Washington, D.C. to expect a more measured approach from SEC Enforcement. That may include, she...more

DLA Piper

DOJ’s Revised Policy on Crediting Fines: Emphasis on Victims

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Without fanfare, the Department of Justice (DOJ or the Department) has published a memorandum revising its policy on when – and how – it will give credit to companies for fines and other payments made to other agencies,...more

Hogan Lovells

RISK RADAR 2025 – Part 1: What’s keeping Middle East GCs awake and what to do about it

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With global tensions rising, data threats growing and regulators sharpening their teeth, 2025 is proving to be a significant year for legal and compliance teams across the Middle East. From secondary sanctions exposure to...more

Seyfarth Shaw LLP

The False Claims Act Comes to Britain? Preparing for the ‘Failure to Prevent Fraud’ Offence

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In just a few months, the UK’s corporate criminal liability offence of Failure to Prevent Fraud (FTPF) comes into force. Modelled on the framework of the Failure to Prevent Bribery offence, FTPF imposes strict liability on...more

Troutman Pepper Locke

Beware of Scam Notices Targeting Trademark Applicants

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Scam notices are being sent to those who have filed trademark applications with the U.S. Patent and Trademark Office (USPTO) or already own a registered mark. The notices are designed to exploit publicly available...more

Foley & Lardner LLP

Customs Fraud Makes the Big Leagues: DOJ’s New White-Collar Priorities Confirm Heightened Risk

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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

The Volkov Law Group

Episode 371 -- DOJ's New Corporate Enforcement Program

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Is your company ready to bet its future on whether it can outpace a whistleblower to the DOJ’s door? In this episode, Michael Volkov takes a deep dive into the Department of Justice’s newly announced strategy to reshape...more

Bradley Arant Boult Cummings LLP

Customs Fraud Investigations Will Be a DOJ Area of Focus

On May 12, 2025, Department of Justice (DOJ) Criminal Chief Matthew Galeotti issued a memorandum addressing the “Fight Against White-Collar Crime.” The memorandum lists several priorities for white-collar criminal...more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for April 2025

Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. For the month when Paul Atkins was sworn in as SEC Chairman, we examine: • The SEC’s...more

Foley Hoag LLP - White Collar Law &...

Are There Legitimate Ways to Achieve More Advantageous Tariff Classifications?

With recent increases in U.S. tariffs and the increasing complexity of determining applicable duties for different products, importers are looking for ways to reduce their tariff exposure. Since a product’s tariff treatment...more

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