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On February 22, 2023, the Department of Justice (DOJ) announced a new Voluntary Self-Disclosure Policy establishing uniform, transparent guidelines for how United States...

Credible reports of criminal violations within a company may cause management’s stomach to sink.

The U.S. Department of Justice has issued its first health care fraud declination under the new Corporate Enforcement Policy, resolving a multi-year investigation into Campus Eye Management for alleged Medicare fraud and Anti-Kickback Statute violations. While the company avoided prosecution through voluntary self-disclosure and cooperation, its CEO faces criminal charges, highlighting DOJ's continued focus on individual accountability even when corporations receive favorable treatment.

With the increased focus by the Obama Administration on financial crimes, health care fraud, and corporate fraud, corporate compliance and ethics programs have never been more important.

A recent Delaware Supreme Court decision, RAA Management LLC vs. Savage Sport Holdings, Inc., underscores the enforceability and scope of non-reliance clauses in confidentiality agreements.

Company-constituent JDAs have long been a valuable tool in corporate investigations and government enforcement litigation.

2024 saw no change in the government's campaign to encourage self-reporting and cooperation. In the second installment of Season's Readings...

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...

Comparing one to the other, the codes may be wrong and the overpayments indisputable.

The Policy's release in September 2015 followed prolonged criticism over a perceived lack of prosecution of individuals responsible for corporate misconduct.

The cost of insider trading just got more expensive for those who get caught. In a February 18, 2014 decision by the U.S. Court of Appeals for the Second Circuit, a split appeals court panel found that an individual held liable for civil insider trading while working at an investment fund can ..

The Corporate Transparency Act is alive and kicking and requiring all community associations that are registered as entities with Arizona's Corporation Commission...

On February 22, 2023, the Department of Justice (DOJ) announced a nationwide Voluntary Self-Disclosure Policy (VSD Policy), which goes into effect immediately and which is meant to strongly encourage self-disclosures.

Obtaining credit for corporations who cooperate with government investigations will only be considered if the corporation provides all relevant facts about individuals involved in corporate misconduct.

This year, the Department of Justice (DOJ) continued to reaffirm the importance of its June 2020 Evaluation of Corporate Compliance Programs, June 2020 guidance (DOJ Guidance)...

A provision in pending financial regulatory legislation would allow whistleblowers in Foreign Corrupt Practices Act ("FCPA") and securities fraud cases to claim a 10 percent to 30 percent bounty in enforcement actions that impose penalties of more than $1 million.

In the wake of the guilty plea entered by Vetco Grey in February 2007, the US Department of Justice (DOJ) has aggressively intensified its investigation into payment practices of those working through the customs process in Nigeria. While some of these investigations have resulted in public statements by companies under review, the activity has yet to cease.

On August 13, 2015, a US district judge dismissed a charge seeking to hold a defendant criminally liable for conspiracy to violate the Foreign Corrupt Practices Act (FCPA) if he is not a principal or agent of a US domestic concern and did not physically enter US territory.