As detailed in Part I of our three-part series on Minimizing Customs Enforcement and False Claims Act Risks, the combination of the new high-tariff environment, the heightened ability of Customs (and the general public) to...more
4/25/2025
/ Anti-Dumping Duty ,
Classification ,
Compliance ,
Countervailing Duties ,
Country of Origin ,
Customs and Border Protection ,
Duty Free ,
Enforcement Actions ,
False Claims Act (FCA) ,
Free Trade Agreements ,
Imports ,
International Trade ,
Misclassification ,
Misrepresentation ,
Penalties ,
Risk Management ,
Tariffs ,
Valuation
A recent United States Department of Justice (DOJ) announcement reinforces that enforcement of cybersecurity requirements under the False Claims Act (FCA) remains an ongoing risk. According to the press release, defense...more
4/4/2025
/ Compliance ,
Corporate Counsel ,
Cybersecurity ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Contractors ,
NIST ,
Qui Tam ,
Risk Management ,
Settlement ,
Subcontractors
On February 20, 2025, the Deputy Assistant Attorney General for the Commercial Litigation Branch at the U.S. Department of Justice (DOJ), Michael Granston, emphasized using the False Claims Act (FCA) to address U.S. Customs &...more
3/7/2025
/ Compliance ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Globally Harmonized System ,
Imports ,
International Trade ,
Misclassification ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trump Administration ,
US Enforce and Protect Act (EAPA) ,
Whistleblowers
Editor’s Note: PYA and Foley & Lardner hosted the 7th Annual “Let’s Talk Compliance” two-day virtual conference on January 23 and 24, 2025. Panelists included Foley attorneys and PYA subject matter experts. The event was...more
3/5/2025
/ Compliance ,
Cybersecurity ,
Data Privacy ,
Department of Government Efficiency (DOGE) ,
Department of Health and Human Services (HHS) ,
Fraud ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
Medicaid ,
Medicare ,
OIG ,
Risk Assessment ,
Third-Party
Although the change in administrations has heralded shifting enforcement priorities at the U.S. Department of Justice (DOJ), cybersecurity enforcement under the False Claims Act (FCA) appears to be alive and well. That is the...more
3/4/2025
/ Compliance ,
Corporate Counsel ,
Cybersecurity ,
Data Security ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Enforcement ,
False Claims Act (FCA) ,
Federal Contractors ,
Health Care Providers ,
Risk Management ,
TRICARE
Share on Twitter Print Share by Email Share Back to top Conducting effective cross-border internal investigations is more critical than ever for companies facing increasingly complex regulatory frameworks across the globe....more
10/10/2024
/ Attorney-Client Privilege ,
California Consumer Privacy Act (CCPA) ,
Compliance ,
Confidentiality Policies ,
Data Privacy ,
General Data Protection Regulation (GDPR) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
India ,
Internal Investigations ,
Japan ,
Multinationals ,
Sweden ,
Whistleblowers
On Monday, September 23, DOJ’s Criminal Division announced updates to its guidance for evaluating corporate compliance programs (“ECCP”). Principal Deputy Assistant Attorney General Nicole Argentieri also delivered remarks...more
9/27/2024
/ Anti-Retaliation Provisions ,
Artificial Intelligence ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Emerging Technologies ,
Incentives ,
Penalties ,
Risk Assessment ,
Risk Management ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Protection Policies ,
Whistleblowers
U.S. Deputy Attorney General Lisa Monaco recently announced that the Department of Justice (DOJ) is adopting a new safe harbor policy to incentivize corporations to voluntarily self-disclose criminal misconduct discovered...more
10/13/2023
/ Acquisitions ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Disgorgement ,
Due Diligence ,
Enforcement ,
Investigations ,
Mergers ,
Safe Harbors ,
Self-Disclosure Requirements
On March 3, 2023, the Department of Justice (DOJ) announced noteworthy updates to its Evaluation of Corporate Compliance Programs (ECCP) guidance. In remarks at the American Bar Association’s National Institute on White...more
On September 15, 2022, Deputy Attorney General Lisa Monaco announced significant changes to the U.S. Department of Justice’s (DOJ) approach to corporate criminal enforcement, including revised policies and an accompanying...more