The United Kingdom (UK), France, and Switzerland announced on 20 March 2025 that they have jointly launched the International Anti-Corruption Prosecutorial Taskforce to combat complex international white-collar crime. The...more
4/3/2025
/ Anti-Corruption ,
Bribery ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Money Laundering ,
Popular ,
Serious Fraud Office (SFO) ,
Switzerland ,
UK ,
White Collar Crimes
As the pending settlement in In re: College Athlete NIL Litigation, Case No. 4:20-CV-03919 (N.D. Cal) (the “House Settlement”) inches toward a final approval hearing before Judge Claudia Wilken on April 7th, a big question...more
On February 20, the U.S. Department of State (State) designated eight cartels as Foreign Terrorist Organizations (FTOs). These designations are the latest development in the Trump administration’s realignment of the U.S....more
Robust immigration enforcement was a consistent theme that the Republican party sounded during the presidential campaign. Since taking office, the second Trump administration has surged into action with remarkable speed,...more
Upon her swearing in on February 5, 2025, Attorney General Pam Bondi issued a series of memoranda to all Department of Justice employees, including a memorandum entitled “Ending Illegal DEI and DEIA Discrimination and...more
On February 10, 2025, President Trump ordered the U.S. Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) and issue new enforcement guidelines that take into consideration U.S....more
On 21 November 2024, hot off a political comeback for the history books, president-elect Donald Trump announced former Florida attorney general Pam Bondi as his nominee for Attorney General. The announcement followed the...more
Ignoring integrity risks in emerging markets when receiving financing from the World Bank Group (WBG) is about to become much riskier, as the WBG Sanctions System Annual Report for Fiscal Year 2022 (FY22) indicates. The...more
12/7/2022
/ Annual Reports ,
Bid Rigging ,
Collusion ,
Corruption ,
Enforcement Actions ,
Federal Contractors ,
Financial Fraud ,
Financial Institutions ,
Financing ,
Fraud ,
International Finance ,
Investigations ,
Private Sector ,
Project Finance ,
Risk-Based Approaches ,
Settlement ,
Suspensions & Debarments ,
World Bank
The American Bar Association’s annual white collar crime conference is often a favorite place for the U.S. Department of Justice to announce new policies and programs, and this year’s meeting in San Francisco was no...more
On January 21, 2022, the Department of Justice (“DOJ”) issued a Foreign Corrupt Practices Act (“FCPA”) Opinion Procedure Release (the “OPR” or “OPR 22-01”) addressing the rarely discussed extortion exception to the FCPA’s...more
On October 28, 2021, Deputy Attorney General (DAG) Lisa O. Monaco gave the keynote address at the ABA’s 36th National Institute on White Collar Crime and announced a series of changes in the Department of Justice’s (DOJ)...more
This month’s analysis looks at individual prosecutions under the Foreign Corrupt Practices Act (FCPA). Prosecutions have markedly increased over the last five years, and this will better define local, regional, and...more
Government recoveries under False Claims Act (FCA) enforcement grew slightly in fiscal year (FY) 2019 to just over $3 billion.
Companies operating in the Aerospace, Defense, and Government Services (ADG) industry continue...more
2/3/2020
/ Aerospace ,
Airlines ,
Defense Contracts ,
Defense Sector ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Contractors ,
Fraud and Abuse ,
Information Technology ,
OEM ,
Software
On November 20, 2019, the U.S. Department of Justice (DOJ) announced several subtle, but important, adjustments to its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. These recent changes relate to...more
More than two years after the Northern District of Alabama granted summary judgment in a False Claims Act (FCA) case in favor of AseraCare Inc., holding that “contradiction based on clinical judgment or opinion alone cannot...more
9/11/2019
/ Bifurcation ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Billing ,
False Claims Act (FCA) ,
False-Certification of Conformance ,
Health Care Providers ,
Healthcare Fraud ,
Hospice ,
Insurance Fraud ,
Life Sciences ,
Medicare ,
Physicians ,
Qui Tam ,
Remand ,
Terminal Illness Treatments ,
Vacated ,
Whistleblowers
In a May 17, 2019 press report that has been widely distributed in Brazil and the United States, Brazilian Federal Prosecutor Marisa Ferrari confirmed that the U.S. Federal Bureau of Investigation (FBI), the U.S. Department...more
5/21/2019
/ Brazil ,
Bribery ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FBI ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Kickbacks ,
Medical Devices ,
Multinationals ,
Pharmaceutical Industry ,
Popular ,
Price-Fixing ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
The pace of False Claims Act (FCA) litigation remained furious over the past year. Companies (and individuals) in all sectors of the economy continue to face the ever-present threat of FCA enforcement whenever they do...more
1/22/2019
/ Department of Justice (DOJ) ,
Digital Realty Trust Inc v Somers ,
Enforcement Actions ,
False Claims Act (FCA) ,
False Implied Certification Theory ,
Fraud ,
Health Information Technologies ,
Implied Certification ,
Materiality ,
Qui Tam ,
SCOTUS ,
Settlement Agreements ,
Universal Health Services Inc v United States ex rel Escobar ,
US Trade Policies ,
Whistleblowers
Government attorneys now have additional discretion in False Claims Act (FCA) civil cases to award cooperation credit to a corporation that meaningfully assists the government’s investigation without necessarily identifying...more
12/4/2018
/ Cooperation Agreement ,
Corporate Crimes ,
Corporate Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Government Investigations ,
Policy Statement ,
Qui Tam ,
White Collar Crimes ,
Willful Misconduct ,
Yates Memorandum
A new plea bargaining system – offering reduced penalties to companies that report certain violations and cooperate with government investigations – will come into effect in Japan this June, reflecting an amendment to the...more