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Seeking to introduce for the first time in this country robust mechanisms to prevent and prosecute against corruption and bribery by persons connected to the UK in the public and private sectors.

The UK’s Financial Services Authority (FSA) published on March 29, 2012, the findings of its "thematic review into anti-bribery and corruption systems and controls in investment banks."

SEC enforcement actions often include allegations that corporate officers affirmatively misled a company’s outside auditors as part of a scheme to commit and perpetuate an accounting fraud.

With the filing of civil and criminal complaints last week against executives of Brocade Communications Systems, Inc., and the SEC’s adoption of new executive compensation disclosure rules on July 26, 2006 (which will require companies to disclose information about their option grant practices), the SEC and the Department of Justice have made it clear that the federal government is committed to exposing and eliminating fraud and criminal misconduct associated with the timing of stock option gran

Government contractors and health care companies have become increasingly concerned about the application of the Wartime Suspension of Limitations Act ("WSLA"), 18 U.S.C. § 3287, and the Department of Justice's ("DOJ") and False Claims Act ("FCA") relators' arguments ..

Recent corporate guilty pleas can be expected to have serious implications for the individual executives and employees alleged to have been involved in the conduct under scrutiny.

Companies should take note and be prepared to respond quickly to more—and more aggressive—EPA enforcement, on the heels of two new enforcement initiatives announced by David Uhlmann...

Nearly 2,200 issuers held "say-on-pay" votes in 2011. Shareholders have overwhelmingly voted in favor of the proposed compensation plans, rejecting management compensation proposals in only about 40 instances.

The Department of Justice has formally launched a three-year pilot of its Corporate Whistleblower Awards Program (Pilot Program), which is likely to increase the number...

Other cases suggest that prosecutors may choose to avoid the challenges posed by the personal benefit test altogether.

In May of last year, Congress enacted a dramatic revision to the substantive provisions of the civil False Claims Act, but left alone the key jurisdictional "public disclosure / original source" bar put in place by Congress in 1986 to avoid parasitic qui tam suits.

On May 12, 2025, the Department of Justice Criminal Division announced significant changes to its corporate white-collar criminal enforcement priorities.

The Department of Justice has established a new National Fraud Enforcement Division to combat fraud involving taxpayer dollars and federally-funded programs. Led by newly confirmed Assistant Attorney General Colin McDonald, this initiative represents a coordinated, whole-of-government approach to investigating and prosecuting white-collar crime that impacts public funds.

The Department of Justice's newly created National Fraud Enforcement Division has issued a memorandum outlining five substantive enforcement priorities that signal an ambitious expansion of federal fraud enforcement resources. With approximately 500 attorneys and staff expected by August 2026 and plans for further growth, the Division will deploy enhanced data analytics and cross-agency coordination to pursue fraud schemes across government procurement, healthcare, tax enforcement, global trade, and corpora

Companies participating in the federal government's TARP program should be aware that the role of the Special Inspector General for the Troubled Assets Relief Program ("SIGTARP") in monitoring and investigating the use of TARP funds - and recommending criminal prosecution for allegedly improper use of such funds—has continued to expand.

In a case that highlights the significance of clarifying the scope of outside corporate counsel's representation of individual employees, the Third Circuit—in an unpublished opinion in United States v. Norris—upheld introducing the testimony of former counsel to the Morgan Crucible Company ("Morgan" or the "Company") against Morgan's former CEO, Ian Norris.

The implications of the Court's decision are significant, and the certainty provided by the Supreme Court is welcome.