Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherJoin the NetworkGet StartedSubscribeSupportContact
Search
Close

Client Alert: DOJ Fraud Division Issues Corporate Enforcement Directive

By David H. Favre, Nimrod Aviad, Derek Hahn, Alexander J. Kramer, Agustin D. Orozco & Preston Pugh on October 6, 2026
Email this postTweet this postLike this postShare this post on LinkedIn

On October 1, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division issued Directive 26-12: Corporate Enforcement in the Fight Against Fraud. Assistant Attorney General Colin M. McDonald’s October directive follows his August 2026 memorandum setting the Division’s enforcement priorities. The directive signals — in the DOJ’s words — “an aggressive, all-tools” enforcement posture across the Division’s health care, government contracting, tax, and trade fraud priorities, while simultaneously supporting the incentives designed to promote transparency, reward cooperation, and encourage voluntary disclosure of misconduct. 

Beyond reinforcing the Division’s priorities, this October directive outlines the factors the Division will give “great weight” to when making corporate charging and plea decisions. Companies operating in the areas of health care, government contracts, and international trade should take particular note. 

Click here to continue reading the full version of this alert.

Photo of David H. Favre David H. Favre

David’s practice focuses on government contracts and white collar matters, including investigations and bid protests.  He draws on his prior service at the U.S. Court of Federal Claims to help counsel government contractors on a range of issues.

David advises clients on government

…

David’s practice focuses on government contracts and white collar matters, including investigations and bid protests.  He draws on his prior service at the U.S. Court of Federal Claims to help counsel government contractors on a range of issues.

David advises clients on government investigations and bid protests before the Government Accountability Office and the U.S. Court of Federal Claims. With the challenge of meeting accelerated timelines and complex bid protest requirements, his prior government experience adds value to the strategies he recommends to clients.

Before joining the firm, David clerked for the Honorable Richard A. Hertling on the U.S. Court of Federal Claims.

While at Georgetown University Law Center, David represented juveniles in delinquency proceedings in D.C. Superior Court with the Juvenile Justice Clinic. He served on the American Criminal Law Review, where he was an editor of the Annual Survey of White Collar Crime articles on health care fraud, Racketeer Influenced and Corrupt Organizations, and false statements and false claims. He also interned for the Honorable Rosemary M. Collyer on the U.S. District Court for the District of Columbia.

David served as a combat engineer in the U.S. Marine Corps. He is a veteran of Operation Enduring Freedom in Afghanistan.

Read more about David H. FavreEmail
Show more Show less
Photo of Nimrod Aviad Nimrod Aviad

Nimrod (Nimi) Aviad is a partner in Crowell & Moring’s Los Angeles office, where he is a member of the White Collar Crime and Regulatory Enforcement Group and of the firm’s Investigations Group.

Nimi’s practice focuses on representing and counseling corporate and individual…

Nimrod (Nimi) Aviad is a partner in Crowell & Moring’s Los Angeles office, where he is a member of the White Collar Crime and Regulatory Enforcement Group and of the firm’s Investigations Group.

Nimi’s practice focuses on representing and counseling corporate and individual clients in white collar criminal defense, regulatory enforcement actions, grand jury investigations, internal corporate investigations, and in related complex civil litigation matters.

Read more about Nimrod AviadEmail
Show more Show less
Photo of Derek Hahn Derek Hahn

Derek Hahn is a partner in Crowell & Moring’s White Collar & Regulatory Enforcement Group and a member of the firm’s Investigation Practice. Derek’s practice focuses on white collar defense, internal investigations, complex litigation, and compliance counseling.  He represents clients in an array…

Derek Hahn is a partner in Crowell & Moring’s White Collar & Regulatory Enforcement Group and a member of the firm’s Investigation Practice. Derek’s practice focuses on white collar defense, internal investigations, complex litigation, and compliance counseling.  He represents clients in an array of government investigations and enforcement actions alleging financial fraud, public corruption, conflicts of interest, counterfeiting, procurement integrity, and health care fraud. Derek has also defended clients in several multi-million dollar environmental enforcement matters at both the federal and state level.

Derek has extensive experience managing matters involving the Foreign Corrupt Practices Act (FCPA) having counseled clients in multiple industries on FCPA matters across six continents. His FCPA experience includes government and internal investigations, third-party due diligence reviews, compliance program and training development, and anti-corruption risk assessments. He has defended multiple FCPA investigations brought by the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC).

Read more about Derek HahnEmail
Show more Show less
Photo of Alexander J. Kramer Alexander J. Kramer

Alexander J. Kramer is a partner in the White Collar and Regulatory Enforcement Group, bringing a wealth of experience from his distinguished career at the United States Department of Justice (DOJ). Alex has extensive experience in white collar crime and investigations, including the…

Alexander J. Kramer is a partner in the White Collar and Regulatory Enforcement Group, bringing a wealth of experience from his distinguished career at the United States Department of Justice (DOJ). Alex has extensive experience in white collar crime and investigations, including the Foreign Corrupt Practices Act (FCPA) and anti-corruption issues, health care fraud, significant fraud by government contractors, public companies, financial institutions, and other entities dealing with the DOJ, the U.S. Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), and related parallel enforcement actions.

Read more about Alexander J. KramerEmail
Show more Show less
Photo of Agustin D. Orozco Agustin D. Orozco

Agustin D. Orozco is a partner in the Los Angeles office and is a member of the firm’s White Collar & Regulatory Enforcement and Government Contracts groups. As a former federal prosecutor, Agustin is a skilled trial lawyer focused on directing complex white…

Agustin D. Orozco is a partner in the Los Angeles office and is a member of the firm’s White Collar & Regulatory Enforcement and Government Contracts groups. As a former federal prosecutor, Agustin is a skilled trial lawyer focused on directing complex white collar cases and investigations, handling contentious and sophisticated pretrial litigation, and successfully proving highly difficult cases at trial. Agustin’s background as a federal prosecutor and government contracts attorney leaves him uniquely situated to help clients where government contracts and white collar intersect.

Agustin represents clients in criminal and civil government investigations and enforcement actions. He also represents and counsels clients on matters involving federal, state, and local government contracts. Agustin has litigated civil False Claims Act (FCA) matters and other government contracts issues, such as disputes, claims, and terminations. He is also experienced in matters involving the Foreign Corrupt Practices Act (FCPA), including conducting investigations abroad and counseling clients on compliance issues.

Read more about Agustin D. OrozcoEmail
Show more Show less
Photo of Preston Pugh Preston Pugh

Preston Pugh helps companies, board committees and large organizations conduct internal investigations and respond to government investigations, often stemming from high stakes whistleblower complaints. He is a partner at Crowell & Moring and co-leads its False Claims Act Practice. For more than 20…

Preston Pugh helps companies, board committees and large organizations conduct internal investigations and respond to government investigations, often stemming from high stakes whistleblower complaints. He is a partner at Crowell & Moring and co-leads its False Claims Act Practice. For more than 20 years, he has helped clients navigate many different types of crises—including commercial and government contract fraud investigations; C-suite corporate ethics concerns; whistleblower retaliation claims; broad-based harassment and discrimination complaints; investigations by Congress; and related litigation. He has been recognized by the Legal 500 for his work in investigations.

Read more about Preston PughEmail
Show more Show less
  • Posted in:
    Administrative and Regulatory, Corporate Governance and Compliance
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

Call us at 1-800-913-0988 or email sales@lexblog.com.

Facebook LinkedIn Twitter RSS
The Library at LexBlog
  • About LexBlog
  • The Field We Built
  • Library at LexBlog
  • Our Beliefs
  • Our Team
  • Contact LexBlog
  • Disclaimer
  • Editorial Policy
  • Terms of Service
  • Get Started
  • Publishing Solutions
  • Compass
  • Submit a Request
  • Support Center
  • System Status
Copyright © 2026, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo