On 23 September 2024, the DOJ announced another significant round of updates to its Evaluation of Corporate Compliance Programs (ECCP) – the guidance document Department of Justice (DOJ) prosecutors use to evaluate the...more
9/27/2024
/ Artificial Intelligence ,
Compliance ,
Corporate Governance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Emerging Technologies ,
Enforcement Actions ,
Risk Assessment ,
Risk Management ,
Whistleblower Protection Policies ,
Whistleblowers
After months of anticipation, the Department of Justice (DOJ) unveiled the details of its new Corporate Whistleblower Awards Pilot Program (the Corporate WB Program or the Program)....more
8/8/2024
/ Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Employees ,
Federal Pilot Programs ,
Pilot Programs ,
Self-Reporting ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
Private equity investment in health care has grown significantly over the past two decades, and the US government is starting to pay attention. Recent announcements by the US Department of Justice (DOJ) and proposals by...more
8/1/2024
/ Anti-Kickback Statute ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Healthcare ,
Healthcare Fraud ,
Investors ,
Private Equity ,
Private Equity Firms ,
Regulatory Oversight ,
White Collar Crimes
In this second episode of our series on the government's response to the Paycheck Protection Program, white collar practitioners Chris Nasson, David Rybicki, Neil Smith, and Hayley Trahan-Liptak discuss the second phase of...more
This article analyzes emerging risks to PE firms that invest in the health care sector by examining the current enforcement landscape and significant FCA litigation; identifies key factors that increase FCA risk for PE firms...more
In this episode, we examine how two criminal defendants are aiming to leverage parallel FCPA investigations by the SEC and the DOJ to build their defense. We’ll also offer our thoughts on the SEC’s new (and improved?)...more
10/6/2020
/ Bribery ,
Coronavirus/COVID-19 ,
Criminal Defense ,
Criminal Investigations ,
Criminal Liability ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Discovery Disputes ,
Due Process ,
Enforcement Actions ,
Evidence ,
Evidentiary Hearings ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Honest Services Fraud ,
Memorandum of Guidance ,
New Guidance ,
OMB ,
Parallel Proceedings ,
Ruth Bader Ginsberg ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
A government inquiry can result in serious consequences for a company or individual. Our new podcast series, Voluntary Disclosure—brought to you by the lawyers in our investigations, enforcement, and white collar practice—is...more
8/3/2020
/ Best Practices ,
Bitcoin ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Initial Coin Offering (ICOs) ,
Investors ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Tokens ,
Securities Transactions ,
Securities Violations ,
Security-Based Swaps ,
U.S. Treasury ,
Unregistered Securities ,
Voluntary Disclosure ,
White Collar Crimes
A government inquiry can result in serious consequences for a company or individual. Our new podcast series, Voluntary Disclosure—brought to you by the lawyers in our investigations, enforcement, and white collar practice—is...more
7/17/2020
/ Bribery ,
Criminal Convictions ,
Denial of Certiorari ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Panama Papers ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Voluntary Disclosure ,
White Collar Crimes
On Wednesday, the U.S. Commodity Futures Trading Commission (“CFTC” or the “Commission”) became the latest government agency to formally set its sights on foreign corruption. ...more