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What the FCPA Criminal Enforcement Pause Means for Companies

Late on February 10, President Trump ordered Attorney General Pam Bondi to “pause” new Foreign Corrupt Practices Act (FCPA) enforcement for 180 days while the U.S. Department of Justice (DOJ) refocuses criminal enforcement of...more

AG Bondi Refocuses DOJ Priorities in New Guidance Documents

On February 5, newly confirmed Attorney General Pam Bondi issued a series of guidance documents refocusing U.S. Department of Justice (DOJ) priorities for the new Administration. In addition to effectuating many of President...more

DOJ Announces Larger FCA Recoveries and More Whistleblower Cases Filed in 2024

On January 15, 2025, the U.S. Department of Justice (DOJ) announced $2.9 billion in total False Claims Act (FCA) recoveries for FY 2024, a slight increase from 2023. In addition to growing recoveries, DOJ announced a new...more

Think Because You Are a Private Company the SEC Is Not Your Problem? Think Again (and review those separation agreements)

What: Twice this month, the Securities and Exchange Commission (SEC) announced settled actions against entities for violating SEC Rule 21F-17(a) related to language in their separation agreements, including one against a...more

DOJ’s “Carrot” Approach to Corporate Enforcement Policy (But Read the Fine Print)

Last Tuesday, the Department of Justice (DOJ) announced the most recent modifications to its Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) in an effort to further encourage companies to...more

2021 FCA Recoveries Bounce Back from Decade-Low . . . Maybe

On February 1, the U.S. Department of Justice (DOJ) announced the second-largest annual total recoveries in the history of the False Claims Act (FCA)—$5.6 billion—for FY 2021 (October 2020 – September 2021)...more

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