News & Analysis as of

Enforcement Compliance Department of Justice (DOJ)

Foley & Lardner LLP

The More Things Change… DOJ’s Latest Cyber Settlement Shows Continued False Claims Act Risk

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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

Jackson Walker

DOJ Enforcing Criminal Penalties When Employers Fail to Comply

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The Department of Justice (DOJ) has issued a memo indicating a significant policy shift to prioritize immigration enforcement and expand the use of criminal statutes to address illegal immigration. The DOJ will support the...more

Fox Rothschild LLP

Corporate Transparency Act Back in Effect: March 21 Is the New Deadline to File Beneficial Ownership Reports

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The Corporate Transparency Act’s (CTA) reporting requirements are officially back in force, requiring non-exempt entities to disclose beneficial ownership information (BOI). This week, a Texas federal court lifted the last...more

Pillsbury Winthrop Shaw Pittman LLP

Reshaped Priorities: Navigating Changes to FCPA and FARA Enforcement

On February 10, 2025, President Donald Trump signed an Executive Order directing the Department of Justice (DOJ) to pause enforcement of the U.S. Foreign Corrupt Practices Act (FCPA), citing concerns over the competitive...more

Jenner & Block

Client Alert: The Trump Administration Calls for a Pause on New FCPA Enforcement, but Don’t Abandon Compliance Programs Just Yet

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In an executive order issued on February 10, 2025 (Executive Order), and a memorandum issued by Attorney General Pam Bondi regarding cartels and transnational criminal organizations on February 5, 2025 (Cartel Memo), the...more

Parker Poe Adams & Bernstein LLP

President Trump Suspends Enforcement of Foreign Corrupt Practices Act

Earlier this week, the White House issued an executive order pausing enforcement of the Foreign Corrupt Practices Act (FCPA). The FCPA prohibits U.S. companies and individuals (as well as some foreign entities) from bribing...more

Porter Hedges LLP

Breaking Alert: New Executive Order Temporarily Pauses FCPA Enforcement

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On February 10, 2025, President Trump signed an executive order (EO) directing the Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days. During this period, Attorney...more

White & Case LLP

FCPA Freeze and Refocus: Is Enforcement Becoming a Tool to Promote U.S. Economic, Foreign Policy and National Security Interests?

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On February 10, 2025, President Trump signed an executive order instructing the Attorney General of the United States to pause enforcement of the Foreign Corrupt Practices Act ("FCPA") and to issue updated guidelines for...more

BakerHostetler

Why Your Company Still Needs to Care About the FCPA (& FEPA)

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This shift in FCPA enforcement priorities is the latest move by the administration in its all-out war against cartels and TCOs that pose a threat to U.S. national security and its stated America First agenda. Additionally,...more

The Volkov Law Group

Taking Stock of the FCPA Fallout (Part III of V)

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What an amazing turn of events? — Who would have predicted that the Trump Administration would take such a bold action in the name of advancing “American Competitiveness.” I admit I did not see this coming — the Trump...more

Davis Wright Tremaine LLP

Analyzing President Biden's Ambitious Cybersecurity Executive Order

In his final days in office, President Biden signed an ambitious executive order to improve the federal government's approach to cybersecurity. Executive Order 14114 ("Executive Order"), issued January 16, 2025, titled...more

Sheppard Mullin Richter & Hampton LLP

Data, Deals, and Diplomacy, Part III: DOJ Issues National Security Final Rule with New Data Compliance Obligations for...

On January 8, 2025, the Department of Justice (“DOJ”) published its final rule addressing Executive Order (E.O.) 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more

McDermott Will & Emery

HHS OIG Releases Updated Nursing Facility Compliance Program Guidance: Quality and Safety Lessons

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Nursing facilities and skilled nursing facilities that participate in the Medicare and Medicaid programs must comply with certain mandatory compliance program requirements of participation (ROPs). Under the Biden...more

Guidepost Solutions LLC

Regulatory Enforcement Trends in the New Administration and What They Mean for Your Company

As the Trump administration ushers in a new era of regulatory policy, businesses are closely monitoring shifts in enforcement trends. Understanding these changes is crucial for navigating the evolving regulatory landscape and...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Safe Drinking Water Act Enforcement: U.S. Department of Justice and Thermal, California Mobile Home Park Enter into Consent Decree

The United States Department of Justice (“DOJ”) on behalf of the federal Environmental Protection Agency (“EPA”) entered into a January 16th Consent Decree (“CD”) with the operators of the Oasis Mobile Home Park (“Park”) for...more

Proskauer - Health Care Law Brief

CMS Publishes Final Rule, Effective January 1, 2025, Addressing the Requirements for Reporting and Returning Overpayments

The standard for an “identified overpayment” under Medicare Parts A–D now aligns with section 1128J(d)(4)(A) of the Social Security Act, which incorporates by reference the Federal False Claim Act’s (the “FCA”) “knowledge”...more

Wiley Rein LLP

CTA Update: Supreme Court Temporarily Lifts Injunction, but Requirements Remain Blocked

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On January 23, 2025, the U.S. Supreme Court issued a ruling that appears to settle – for now – a nearly two-month-long legal battle over the Corporate Transparency Act (CTA), which began with a nationwide preliminary...more

Jackson Lewis P.C.

Rescinded Biden Immigration Executive Orders: What Employers Need to Know

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As many expected, President Donald Trump has not only issued Executive Orders (EOs), but he has also rescinded many EOs issued by the Biden Administration concerning immigration, including the following: “The Restoring Faith...more

Amundsen Davis LLC

U.S. Supreme Court Provisionally Reinstates the Corporate Transparency Act

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The U.S. Supreme Court issued an order on January 23, 2025, which provisionally reinstates the Corporate Transparency Act (CTA) while a legal challenge to it continues. This brief order, which stayed an injunction against the...more

McGlinchey Stafford

Stericycle Agrees to Pay $9.5 Million Civil Penalty for RCRA Violations

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On January 17, 2025, the Environmental Protection Agency (EPA) and the Department of Justice (DOJ) announced a $9.5 million settlement with Stericycle, Inc. for Hazardous Waste Management Violations. The settlement resolves...more

Paul Hastings LLP

Private Company Report: Fourth Quarter 2024

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This edition of the Private Company Report highlights critical updates and regulatory changes affecting private companies, including a temporary stay on the enforcement of the new beneficial ownership reporting requirements...more

Mintz - Health Care Viewpoints

EnforceMintz — 2024’s Key False Claims Act Settlements Involving Hospitals and Health Systems: Continued Focus on Stark Law and...

In 2024, the Department of Justice (DOJ) resolved several noteworthy False Claims Act (FCA) cases against hospitals and health systems. In particular, DOJ obtained a number of large recoveries in cases where Stark Law and...more

Farella Braun + Martel LLP

What’s Ahead as Corporate Transparency Act Comes to a Crossroads

The recent whiplash regarding the validity of the Corporate Transparency Act (CTA)—it was enjoined just to particular parties, then enjoined nationwide, then un-enjoined, then enjoined again, while other courts let it...more

McCarter & English Blog: Government Contracts...

Antitrust Corporate Compliance Programs: Late 2024 Changes Mean Companies Should Revisit Their Programs Early in 2025

The US Department of Justice Antitrust Division (DOJ or Division) recently released a revised Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations (Guidance). The Guidance reflects how the Division...more

Ropes & Gray LLP

DOJ Issues Final Rule Restricting Flow of Bulk Sensitive Personal Data to China and Other Countries of Concern

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On January 8, 2025, the Department of Justice (“DOJ”) published its Final Rule to implement President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States...more

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