On October 8, 2019, the US Department of Justice (DOJ or Justice Department) issued new guidance on evaluating inability-to-pay arguments in a memorandum to the Criminal Division. The memorandum provides considerably more...more
10/11/2019
/ Corporate Counsel ,
Corporate Crimes ,
Corporate Criminal Fines ,
Corporate Misconduct ,
Criminal Penalties ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Failure To Pay ,
Federal Sentencing Guidelines ,
New Guidance ,
White Collar Crimes
On May 6, 2019, the Justice Department issued new policies establishing how defendants in False Claims Act (FCA) matters can earn credit for voluntary self-disclosure, cooperation, and remediation, possibly reducing what...more
5/8/2019
/ Compliance ,
Cooperation ,
Damages ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
New Guidance ,
Penalties ,
Remediation ,
Scienter ,
Voluntary Disclosure
As reflected in recent remarks by Deputy Attorney General Rod Rosenstein, the United States Department of Justice (DOJ) is “reinforcing its relationship with good corporate citizens” by coordinating with, and considering, the...more
3/18/2019
/ Anti-Kickback Statute ,
Code of Conduct ,
Corporate Integrity Agreement ,
Corporate Misconduct ,
Criminal Investigations ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Frivolous Lawsuits ,
New Guidance ,
OIG ,
Relators ,
The Granston Memo
On October 12, 2018 in remarks made at the NYU School of Law Program on Corporate Compliance and Enforcement’s Conference on Achieving Effective Compliance, Assistant Attorney General for the U.S. Department of Justice...more
On January 25, Associate Attorney General Rachel Brand issued a memorandum to all components of the Department of Justice with civil litigating authority limiting the use of agency guidance documents in affirmative civil...more