Higher educational institutions have experienced outsized attention in the early days of the second Trump Administration. A trio of three recent executive orders suggests that the Administration’s focus on higher education is...more
4/28/2025
/ Accreditation ,
Colleges ,
Department of Education ,
Diversity and Inclusion Standards (D&I) ,
Executive Orders ,
False Claims Act (FCA) ,
Federal Funding ,
Higher Education Act ,
Historically Black Colleges and Universities (HBCU) ,
Trump Administration ,
Universities
As the business community adjusts to the reality of the Trump Administration’s sweeping new tariff regime, importers and other organizations that rely on imports should be mindful that with the expansion and sharp increases...more
4/22/2025
/ Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Importers ,
Imports ,
International Trade ,
Penalties ,
Tariffs ,
Trump Administration ,
Whistleblowers
Deputy Assistant Attorney General Michael Granston laid out the Department of Justice’s (“DOJ”) priorities over the next four years at the Federal Bar Association’s annual qui tam conference in Washington, D.C. last week....more
On Friday, February 7, the National Institutes of Health (“NIH”) issued Policy Statement Supplemental Guidance affecting budgets both for active grants and for future grants, which was set to take effect on Monday, February...more
2/14/2025
/ Administrative Procedure Act ,
Breach of Contract ,
Colleges ,
Contract Terms ,
Federal Funding ,
Federal Grants ,
Government Agencies ,
Guidance Update ,
Medical Research ,
Pending Litigation ,
Policy Statement ,
Preliminary Injunctions ,
Scientific Research ,
Universities
On February 5, 2025, U.S. Attorney General Pam Bondi issued a series of fourteen policy memoranda directed to all employees of the U.S. Department of Justice (“DOJ”). Two are particularly likely to impact companies and higher...more
The first weeks of the Trump Administration have created substantial uncertainty within Dorsey’s client base, with many clients assessing their partnerships with the United States government and asking whether they have legal...more
2/4/2025
/ Administrative Procedure ,
Administrative Procedure Act ,
Contract Termination ,
Corporate Counsel ,
Federal Contractors ,
Federal Funding ,
Federal Grants ,
Government Agencies ,
Public Contracts ,
Termination ,
Trump Administration
On January 27, the Acting Director of the Office of Management & Budget issued a new Memorandum (M-25-13) that presages significant disruption—if not outright cancellation—of many federal assistance awards. ...more
1/29/2025
/ Educational Institutions ,
Executive Orders ,
Federal Funding ,
Federal Grants ,
Government Agencies ,
Nonprofit Research Organizations ,
Nonprofits ,
OMB ,
Regulatory Agenda ,
Research and Development ,
SBA ,
Scientific Research ,
Universities
The U.S. Department of Justice (DOJ) recently released the fiscal year (FY) 2024 (October 1, 2023 – September 30, 2024) statistics on qui tam and non-qui tam actions under the False Claims Act, 31 U.S.C. § 3729, et seq....more
1/28/2025
/ Cybersecurity ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Statistics ,
False Claims Act (FCA) ,
Healthcare Fraud ,
Medicare Advantage ,
Opioid ,
Qui Tam ,
Settlement ,
Whistleblowers
Alaska Native Corporations have been legally permitted to preferentially hire their shareholders based on a 1992 amendment to a federal statute enacted in the Alaska Native Claims Settlement Act – Section 1626(g). In other...more
1/28/2025
/ Affirmative Action ,
Civil Rights Act ,
Diversity ,
Diversity and Inclusion Standards (D&I) ,
Executive Orders ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Native American Issues ,
Shareholders ,
Supremacy Clause ,
Title VI ,
Title VII ,
Tribal Corporations ,
Trump Administration
On January 21, the President issued an Executive Order with significant impact for Federal contractors and grantees. The EO upsets settled rules related to affirmative action plans and Department of Labor enforcement...more
1/23/2025
/ Affirmative Action ,
Department of Labor (DOL) ,
Diversity and Inclusion Standards (D&I) ,
Employment Discrimination ,
Employment Policies ,
Enforcement Priorities ,
Executive Orders ,
False Claims Act (FCA) ,
Federal Contractors ,
OFCCP ,
Public Employees ,
Qui Tam ,
Trump Administration ,
Whistleblowers
Employers with Federal contracts have experienced unique challenges in the past few years—from navigating the Federal contractor vaccine mandate to new rules related to sick leave and time off. One of the most significant...more
11/21/2024
/ Biden Administration ,
Compensation & Benefits ,
Davis-Bacon Act ,
Department of Labor (DOL) ,
Executive Orders ,
Federal Contractors ,
Federal Procurement Systems ,
Federal Property and Administrative Services Act (FPASA) ,
Final Rules ,
Minimum Wage ,
Obama Administration ,
OFCCP ,
Prevailing Wages ,
Service Contract Act ,
Split of Authority ,
Trump Administration ,
Wage and Hour
The day-to-day operations of healthcare and the Rules of Evidence might seem unrelated, but in today’s enforcement environment, legal and compliance professionals can find, in evidentiary rules, best practices for creating a...more
On September 23, 2024, the U.S. Department of Justice (“DOJ”) released updates to its Evaluation of Corporate Compliance Programs policy (the “Updated ECCP”), building upon the March 2023 updates. Since 2017, DOJ has offered...more
9/27/2024
/ Artificial Intelligence ,
Chief Compliance Officers ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement ,
Internal Controls ,
Policy Memorandums ,
Risk Assessment ,
Technology ,
Voluntary Disclosure ,
Whistleblower Protection Policies
Cybersecurity requirements for federal contractors and grantees continue to proliferate—and those requirements do not just come with contractual risk. Increasingly, the United States government is leveraging enforcement...more
9/5/2024
/ Compliance ,
Cybersecurity ,
Cybersecurity Maturity Model Certification (CMMC) ,
Data Security ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
DFARS ,
Enforcement Actions ,
False Claims Act (FCA) ,
False Statements ,
Federal Contractors ,
Fraud ,
Self-Certification ,
Universities ,
Whistleblowers
The federal government awards billions of dollars each year in sponsored research funding to institutions of higher education, academic research institutions, non-profit organizations, and companies—making federal grants an...more
5/30/2024
/ Accounting ,
Accounting Standards ,
Educational Institutions ,
False Claims Act (FCA) ,
False-Certification of Conformance ,
Federal Funding ,
Federal Grants ,
Federal Rules of Civil Procedure ,
Fraudulent Inducement ,
Materiality ,
National Institute of Health (NIH) ,
Pleading Standards ,
Research and Development ,
Sponsors ,
Whistleblowers
Last week Deputy Attorney General Lisa Monaco announced that the U.S. Department of Justice (DOJ) will soon begin a pilot program to reward whistleblowers who alert prosecutors to significant corporate misconduct. The goal of...more
3/15/2024
/ CFTC ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Enforcement Priorities ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
The U.S. Department of Justice (DOJ) announced recently that settlements and judgments under the False Claims Act, 31 U.S.C. § 3729, et seq. (FCA) totaled approximately $2.7 billion in FY 2023 (October 1, 2022 – September 30,...more
3/12/2024
/ Civil Investigation Demand ,
Coronavirus/COVID-19 ,
Cybersecurity ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Enforcement Statistics ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare Fraud ,
Kickbacks ,
Medicare Advantage ,
Paycheck Protection Program (PPP) ,
Qui Tam ,
Third-Party Liability ,
Whistleblowers
According to the National Center for Science and Engineering Statistics (“NCSES”), a key driver in the scientific and technological accomplishments of U.S. research universities is the volume of federal support for research...more
9/7/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
China ,
Colleges ,
Department of Defense (DOD) ,
Economic Sanctions ,
Educational Institutions ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Federal Funding ,
Foreign Entities ,
Foreign Policy ,
National Security ,
Popular ,
Research and Development ,
Russia ,
Scientific Research ,
SDN List ,
State-Owned Enterprises ,
Universities
On April 5, the U.S. Treasury Department's Office of Foreign Assets Control (“OFAC”) in the U.S. Department of the Treasury named Genesis Market to OFAC’s Specially Designated Nationals List (“SDN List”). Genesis Market is...more
4/27/2023
/ Cryptocurrency ,
Cyber Crimes ,
Cyber Threats ,
Dark Web ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
FBI ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Online Platforms ,
Russia ,
SDN List ,
U.S. Treasury
The government has been actively investigating and prosecuting Paycheck Protection Program (“PPP” or the “Program”) fraud ever since the Small Business Administration (“SBA”) rolled out the Program in the Spring of...more
Lately, litigation news related to public and private workplace COVID-19 vaccine mandates has quieted. That changed last Friday, when the Eleventh Circuit Court of Appeals narrowed a nationwide injunction against the...more
9/2/2022
/ Appeals ,
Biden Administration ,
Centers for Disease Control and Prevention (CDC) ,
Coronavirus/COVID-19 ,
Employer Mandates ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Injunctions ,
OSHA ,
Preliminary Injunctions ,
Vaccinations ,
Workplace Safety
In the Spring of 2020, the Small Business Association (“SBA”) began administering the Paycheck Protection Program (the “PPP” or the “Program”) to provide SBA-backed loans to help eligible businesses maintain their workforces...more
10/1/2021
/ Certification Requirements ,
Coronavirus/COVID-19 ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Lenders ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
SBA ,
SBA Lending Programs ,
Small Business
Civil litigation by private parties alleging False Claims Act (“FCA”) violations related to Paycheck Protection Program (“PPP”) fraud appears to be heating up. On September 22, 2021, a former restaurant manager filed a...more
The United States Innovation and Competition Act (“USICA”) passed the Senate on June 8, 2021. The bill, a rare bipartisan effort, would pour funding into research, design, and manufacturing initiatives in key technological...more
6/18/2021
/ Biden Administration ,
Buy America ,
Colleges ,
Critical Infrastructure Sectors ,
Executive Orders ,
Federal Funding ,
Federal Grants ,
Infrastructure ,
Made in the USA ,
Manufacturers ,
National Science Foundation ,
Pending Legislation ,
Research and Development ,
Semiconductors ,
STEM ,
Technology Sector ,
U.S. Commerce Department ,
Universities
On January 12, 2021, the Eastern District of California entered into a civil settlement with a Paycheck Protection Program (“PPP”) borrower and its CEO to resolve allegations of fraud. The settlement stemmed from a $350,000...more
1/15/2021
/ CARES Act ,
Chapter 11 ,
Commercial Bankruptcy ,
Criminal Prosecution ,
Enforcement Actions ,
False Claims Act (FCA) ,
FIRREA ,
Fraud ,
Paycheck Protection Program (PPP) ,
Qui Tam ,
Settlement