In this blog post, we provide an overview of the updates to the Criminal Division’s Corporate Enforcement Policy (CEP) and discuss the impact of these changes on the corporate enforcement policies for criminal violations of sanctions and export controls, criminal
Investigations and Enforcement Blog
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The Top Ten Asia-Pacific FCPA Enforcement Actions of 2022
In a surprising break from past trends for US enforcement of the Foreign Corrupt Practices Act (FCPA), none of the five corporate enforcement actions resolved by the US Department of Justice (DOJ) in 2022, and only two of the six…
DOJ Notches a Win in Its Fight Against Anticompetitive Labor-Market Practices, but Victory at Trial Is Far from Assured
The Department of Justice (DOJ) Antitrust Division secured another labor-side antitrust prosecution win earlier this month in United States v. Patel, a case centered on an alleged no-poach and non-solicitation agreement among Pratt & Whitney and several of its subcontractors,…
Department of Justice KleptoCapture Task Force – Director Andrew Adams Shares Observations on Current Efforts and Expected Developments
The Department of Justice (DOJ) “KleptoCapture” Task Force (the “Task Force”), launched shortly after Russia’s invasion of Ukraine earlier this year, is characterized by DOJ as a key part of the current Administration’s broader anti-corruption initiative. The role of the…
The Zito Plea: The Antitrust Division’s First Section 2 Criminal Prosecution In 41 Years Is Not All It’s “Cracked” Up to Be
On October 31, 2022, Nathan Nephi Zito pleaded guilty in the US District Court for the District of Montana for his attempt to monopolize the markets for highway crack-sealing services in Montana and Wyoming. This marks the first win for…
First to File: Issue 5
In this issue:
- A settlement involving a construction company that improperly claimed credit for using disadvantaged business entities on federally-funded New Jersey construction contracts that did not actually perform the work.
- An Anti-Kickback Statute case where the district court denied
…
First to File: Issue 3
Time for another update…
The United States Asserts Its Position on Rule 9(b) Before Supreme Court in Response to Owsley Cert Petition
The Solicitor General’s office has once again expressed its view that the Supreme Court should deny a petition…
First to File: Issue 2 (The week of Sept. 5-9, 2022)
Judicial Decisions
United States ex rel. Mackillop v. Grand Canyon Education, Inc., et al., 2022 WL 4084444 (D. Mass.)
Industry: Higher Education
Topics: Materiality, Scienter
In Mackillop, the relator, a university counselor, brought suit against Grand Canyon Education, Inc., an…
What to Expect Next? US Economic Sanctions and Export Controls Enforcement Actions Thus Far in 2022
This year, we have witnessed an extraordinary set of coordinated economic sanctions and export control regulatory actions against Russia after its invasion of Ukraine. In contrast to the fast and furious pace of regulatory action, enforcement actions did not keep…
Court Orders Attorney Notes Protected in Former Citi Trader’s Lawsuit Against Former Employer
On June 15, 2022, the District Court for the Southern District of New York dealt a blow to former Citigroup Inc. (Citi) trader Rohan Ramchandani in his malicious prosecution lawsuit against his former employer.[1] Magistrate Judge Stewart D. Aaron…