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Recent Decisions and DOJ Policy Announcements Signal Key Changes to FCA Enforcement and Litigation Environment

Recent legal and political False Claims Act (“FCA”) developments signal a potentially turbulent time for the defense of investigations and lawsuits brought under the FCA...more

The Department of Justice Announces a New Program to Pay Financial Rewards to Whistleblowers for Information About Corporate...

On March 7, 2024, Deputy Attorney General Lisa Monaco announced that the Justice Department intends to offer new financial incentives for whistleblowers to report allegations about white collar crimes that result in asset...more

Foreign Extortion Prevention Act (FEPA)

How the New Law Creates Legal Risks and Opportunities for International Businesses - On December 22, 2023, President Biden signed into law the 2024 National Defense Authorization Act (NDAA), which will give the U.S....more

Reconsider That Term Sheet: DOJ "Safe Harbor Policy" Announcement Incentivizes Merger-Related Disclosures

On October 4, 2023, the Department of Justice’s (“DOJ”) Deputy Attorney General Lisa Monaco announced a new “Mergers & Acquisitions Safe Harbor Policy” (“M&A Safe Harbor Policy” or “Policy”) for companies that voluntarily...more

Cooperation Credit and Attorney-Client Privilege: The Implications of Coburn

Cognizant Technology’s Privilege Waiver - On February 1, 2022, the District of New Jersey ordered a company to produce internal investigation materials to two former executives indicted in connection with an alleged foreign...more

DOJ Announces FCA Settlement with NIH-Funded Institute Related to Disclosure of Foreign Influence in Research

The Department of Justice (DOJ) recently announced that it reached a $5,500,000 settlement with a biomedical research institute that received NIH grant funding–the Van Andel Research Institute (VARI)–to resolve allegations...more

DOJ Issues Guidance for Evaluating a Business Organization's Inability to Pay a Criminal Fine or Penalty

On October 8, 2019, Assistant Attorney General Brian A. Benczkowski issued a memorandum to the Criminal Division of the U.S. Department of Justice (“DOJ” or “the Department”) that established a framework for assessing...more

Echoes of the Brand Memo: Agencies Issue Statements Limiting the Use of Guidance Documents

Following the lead of the Department of Justice, several agencies issued statements disclaiming guidance as legally binding authority. The Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation,...more

DOJ Issues Memorandum Urging Government Lawyers to Dismiss ‘Meritless’ False Claims Act Cases

The Department of Justice recently issued an internal guidance memo to DOJ attorneys regarding the dismissal of meritless False Claims Act (FCA) cases. Michael Granston, the Director of DOJ’s Civil Fraud Section, first made...more

The Brand Memorandum: DOJ Restricts Reliance on Agency Guidance in Civil Enforcement Actions

On January 25, 2018, Associate Attorney General Rachel Brand issued a memorandum significantly restricting Department of Justice (“DOJ” or “the Department”) civil litigating units’ use of executive agency guidance documents...more

Global Investigations Review Conference Highlights the Future of Anti-Corruption Enforcement Recapping GIR Live DC

On February 16, 2017, Global Investigations Review (“GIR”) held its second annual GIR Live DC in Washington, D.C. With an emphasis on global anticorruption enforcement, the event featured a variety of experts in complex,...more

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