On May 12, 2025, the Department of Justice (DOJ) announced revisions to its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). As stated by Matthew Galeotti, head of the DOJ’s Criminal Division, the purpose of the revised CEP is to incentivize companies to “come forward, come clean, reform, and cooperate with the government in efficient investigations
In August 2025, the U.S. Department of Justice (DOJ) declined to prosecute an insurance company for alleged violations of the Foreign Corrupt Practices Act (FCPA), marking the first action of its kind since the DOJ paused FCPA prosecutions earlier this year. DOJ’s decision came in response to the company’s voluntary self-disclosure. Importantly, this decision allows the company to avoid criminal charges in connection with bribes allegedly paid by employees of its foreign subsidiary for customer referrals for products. As part of the resolution with DOJ, the company will disgorge approximately $4.7 million in profits that are tied to the misconduct.
On September 23, we launched our Government Enforcement, Compliance & Investigations webinar series, a new monthly webinar program covering Department of Justice criminal enforcement, False Claims Act, antitrust, and state attorney general topics.
In the kickoff webinar, Jody Rudman, Wendy Arends, Matt Diehr, and I joined in a broad discussion on government enforcement. Jody and I
On August 29, 2025, the Department of Justice (DOJ) launched a new Trade Fraud Task Force, which will leverage resources from DOJ’s Civil and Criminal Divisions as well as the Department of Homeland Security (DHS) to enforce tariff and duties evasion, smuggling, and other import violations. The initiative furthers the Trump Administration’s “America First Trade Policy” announced on Inauguration Day and in Executive Order 14243, which promotes information-sharing between agencies to support the administration’s overall goals of combating waste, fraud, and abuse.
We’ve just put the wraps on Episode 31 of the False Claims Act Insights podcast where I had a great conversation with longtime healthcare law veterans Brett McNeal and David Traskey covering advisory opinions from the Department of Health and Human Services’ Office of Inspector General. We discuss how the highly qualified and sometimes equivocal