False Claims Act: Implied Certification Theory
On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more
Deutsche Bank’s ethics and compliance function faces numerous challenges. Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....more
I thought Frosty was a good analogy to consider the disgraced Goldman Sachs Group Inc.’s former partner Tim Leissner, as he is certainly back again. Yesterday, I begin a two-part blog post series on Leissner’s settlement with...more
As reported by Byron Tau and Aruna Viswanatha in the Wall Street Journal (WSJ), “Jho Low, the businessman-turned-fugitive accused of masterminding a multibillion-dollar fraud involving Malaysia’s sovereign-wealth fund, agreed...more