We previously offered insight into two False Claims Act (“FCA”) enforcement actions brought by the U.S. Department of Justice (“DOJ”) as part of its “Civil Cyber-Fraud Initiative” (“CCF Initiative”). Deputy Attorney General Lisa O. Monaco announced the CCF Initiative in
There has been no shortage of news this month, so it is understandable that a major presidential proposal garnered relatively little attention at the time. On March 2, the President proposed a sweeping pandemic anti-fraud initiative that is designed to
Our colleagues at Capital Thinking have been monitoring this week’s veto by President Biden of a Republican-led effort to overturn a Department of Labor rule on environmental, social, and governance (ESG) guidelines for retirement accounts. Given the topic, and how
On Friday, March 3, 2023, the DOJ released its updated Evaluation of Corporate Compliance Programs, which included new guidance on ephemeral messaging platforms and other issues. This new guidance was released contemporaneously with Assistant Attorney General Kenneth A. Polite,
At last week’s American Bar Association’s 38th Annual National Institute on White Collar Crime, both Deputy Attorney General Lisa O. Monaco and Assistant Attorney General Kenneth A. Polite, Jr. provided additional insight into the DOJ’s continued focus on corporate criminal
On March 2, 2023, the Department of Justice announced several new initiatives that prioritize the investigation and enforcement of economic sanctions evasion, export control violations, and similar economic crimes. Deputy Attorney General Lisa Monaco announced a “surge of resources to
On February 22, 2023, the Department of Justice (“DOJ”) announced the new United States Attorneys’ Offices Voluntary Self-Disclosure Policy (“VSD Policy”). Following on the heels of the Criminal Division’s revised Corporate Enforcement Policy, the VSD Policy was also developed
Last week, the U.S. Department of Justice (DOJ) and U.S. Department of Commerce (Commerce) announced the creation of a “Disruptive Technology Strike Force.” The strike force will be co-led by DOJ’s National Security Division and Commerce’s Bureau of Industry and
On January 24, 2023, the Federal Reserve Board (“FRB”) assessed a second-tier[1] civil penalty of $2.3 million against New York-based Popular Bank (or the “Bank”) for unsafe and unsound practices related to six Paycheck Protection Program (“PPP”) loans. According
About this time last year, we offered some insight on Economic Espionage and Theft of Trade Secrets, which included a primer on economic espionage, case examples, and avoidance strategies. We observed that “[w]hile the Office of the Director of
