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Government Investigations Team Insights - July 2024

AGG’s Government Investigations Team Insights provides periodic updates covering legal and regulatory topics. Our team, which includes former federal prosecutors, SEC enforcement attorneys, and federal agency attorneys, has...more

Q&A With Allison Raley: Defending Against Government Investigations

Q: What are the primary areas of focus in your practice related to government investigations? A: My practice primarily focuses on defense against enforcement actions brought by regulatory bodies such as the Office of Foreign...more

"If You Most Know, You Know”: Expert Testimony That “Most” Drug Couriers Know They’re Carrying Drugs Allowed to...

If you know, you know. The government’s less familiar version — if most know, the defendant knows — just got a boost from the Supreme Court of the United States, which recently held that Federal Rule of Evidence 704(b) did...more

DOJ Announces New Safe Harbor Policy for Mergers and Acquisitions

As part of a continuing and extensive effort this year to update and strengthen Department of Justice (“DOJ”) policies aimed at deterring corporate misconduct, the DOJ announced on October 4, 2023, that it was implementing a...more

Government Investigations Team Insights - September 2023

AGG’s Government Investigations Team Insights provides periodic updates covering legal and regulatory topics. Our team, which includes former federal prosecutors, SEC enforcement attorneys, and federal agency attorneys, has...more

The Government Cannot Cut Corners: Appellate Courts Reverse Sentences in Three Recent Cases Because the Government Did Not...

Three appellate courts recently reversed sentences because the government did not adequately present evidence to support the alleged loss calculation underlying the court’s determination of the sentencing guidelines range. In...more

Senate Introduces Bill Amending False Claims Act Materiality Element and Anti-Retaliation Provision Expanding Liability

On July 25, 2023, Sens. Chuck Grassley (R-IA), Dick Durbin (D-IL), John Kennedy (R-LA), and Roger Wicker (R-MS) introduced the False Claims Amendments Act of 2023. The proposed amendment to the False Claims Act does not...more

SCOTUS Rejects Objective Knowledge Standard in False Claims Act; Defendant’s Subjective Belief Is Key to Scienter

In a unanimous opinion issued on June 1, 2023, the Supreme Court of the United States clarified the relevant standard for scienter — or knowledge — in False Claims Act (“FCA”) actions by ruling that an objectively reasonable...more

Sixth Circuit Affirms Dismissal of Anti-Kickback Statute-Based False Claims Act Complaint

The United States Court of Appeals for the Sixth Circuit recently affirmed an order dismissing a qui tam False Claims Act (“FCA”) suit based on alleged violations of the Anti-Kickback Statute (“AKS”). The appeals court agreed...more

DOJ Announces More Corporate Enforcement Policies Coordinating Its Attack on Corporate Malfeasance

On the heels of its revised Corporate Enforcement Policy announced in January 2023, the Department of Justice (“DOJ”) announced more policies aimed at prosecuting and deterring corporate misconduct. In late February and early...more

Government Investigations Team Insights - February 2023

AGG’s Government Investigations Team Insights provides periodic updates covering legal and regulatory topics. Our team, which includes former federal prosecutors, SEC enforcement attorneys, and federal agency attorneys, has...more

New DOJ Corporate Enforcement Policy Places Still More Pressure on Companies to Cooperate and Self-Report

Last month in a speech at Georgetown University Law Center, Assistant Attorney General Kenneth A. Polite, Jr., announced revisions to the Department of Justice’s Corporate Enforcement Policy, to apply to all corporate...more

The Pitch - February 2023

The Pitch newsletter is a monthly update of legal issues and news affecting or related to the music, film and television, fine arts, media, professional athletics, eSports, and gaming industries. The Pitch features a diverse...more

Invoking the Protection of the Fifth Amendment Is Your Right and It’s the Right Thing to Do

“[A]ny lawyer worth his salt will tell the suspect in no uncertain terms to make no statement to police under any circumstances.” – Watts v. Indiana, 338 U.S. 49 (1949) (Justice Jackson, concurring) - “Tried to take the...more

DOJ Recovers Over $2 Billion in False Claims Act Cases Last Year, But a Majority of the Funds Were From Cases That the Government...

On February 7, 2023, the Department of Justice released its report on False Claims Act Settlements and Judgments for Fiscal Year 2022, showing that the DOJ recovered over $2.2 billion last year. That same day, in his State of...more

Government Investigations Team Insights - September 2022

AGG’s Government Investigations Team Insights provides periodic updates covering legal and regulatory topics. Our team, which includes former federal prosecutors, SEC enforcement attorneys, and federal agency attorneys, has...more

Insider Trading Cases Back on the Rise . . . With a Twist

Pillow talk from an FBI agent trainee. A former congressman turned consultant trading on merger information learned on the job. A former Goldman Sachs investment banker misappropriating information about deals the bank was...more

Eighth Circuit Says “But For” Causation Required in False Claims Act Case Based on an Alleged Anti-Kickback Violation

On July 26, 2022, the Eighth Circuit raised the bar for plaintiffs seeking to allege a violation of the False Claims Act (“FCA”) predicated on the Anti-Kickback Statute (“AKS”). Under this decision, the plaintiff must prove...more

DOJ Continues Its Annual Coordinated Healthcare Fraud Takedown

In a continuation of its annual rite, the Department of Justice (“DOJ”) on July 20, 2022, announced healthcare-related criminal charges against 36 defendants in 13 federal districts around the U.S. The charges allege more...more

Government Investigations Team Insights - February 2022

AGG’s Government Investigations Team Insights provides periodic updates covering legal and regulatory topics.  In this edition, we analyze a recent Eleventh Circuit decision addressing False Claims Act penalties and the...more

What We Can Learn From Recent PPP Loan and COVID Fraud Cases

Since April 2020, through the CARES Act, the government has provided billions of dollars in emergency financial assistance to Americans suffering from the economic effects caused by the COVID-19 pandemic, including through...more

Is There a Constitutional Limit to Excessive Fines in False Claims Act Cases? Eleventh Circuit Says a Million Dollar Fine for a...

In late December, the U.S. Circuit Court of Appeals for the Eleventh Circuit issued its decision in Yates v. Pinellas Hematology & Oncology, P.A. The appellate court affirmed the district court’s imposition of damages and...more

Government Investigations Team Insights - December 2021

AGG’s Government Investigations Team Insights provides periodic updates covering legal and regulatory topics.  In this edition, we discuss recent criticism of the Justice Department’s use of “taint teams” to review...more

Private Equity Investors at Risk: A New Defendant in False Claims Act Cases?

As a generally held principle, mere investment or ownership interest in a company does not expose the investor to liability for acts undertaken by the company. However, that principle is being called into question in the...more

Government Investigations Team Insights - August 2021

AGG’s Government Investigations Team Insights provides periodic updates covering legal and regulatory topics.  In this edition, we discuss a recent Florida district court case involving prosecutorial misconduct resulting...more

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