Mandatory disclosure obligations significantly changed for federal grant recipients, sub-recipients, and applicants on October 1, 2024. The amended federal regulation establishing these mandatory disclosures (2 C.F.R. § 200.113) not only expands the scope of conduct that must be reported but it also lowers the standard of evidence triggering the mandatory disclosure. The regulation, which is
On September 23, 2024, the U.S. Department of Justice (DOJ) revised its Evaluation of Corporate Compliance Programs (ECCP). The revisions addressed several areas, including whistleblower protections and the role of data analysis. But of particular note, the updated ECCP now
Companies who submit healthcare claims to private payors, provide financial services to customers, interact with domestic or foreign public officials, or otherwise operate in highly regulated industries should take note that the Department of Justice (DOJ) has taken another significant step in its ongoing effort to encourage new whistleblowers with information about potential corporate criminal
On Thursday, May 9, 2024, the Department of Justice announced the formation of a new task force to guide antitrust enforcement in the healthcare industry. The body, named the Task Force on Health Care Monopolies and Collusion (HCMC), is housed within DOJ’s Antitrust Division and directed by longtime DOJ antitrust prosecutor Katrina Rouse.
On April 15, the U.S. Department of Justice released The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the “Pilot”) designed to encourage individuals to report certain types of criminal activity in return for protection from prosecution. The Pilot follows the DOJ’s previously announced plan to create a new initiative expanding the existing whistleblower
On April 20, 2023, the Department of Justice announced criminal charges against 18 defendants in nine federal districts, alleging over $490 million in alleged theft from federally funded COVID-19 relief programs. This clearly shows that, even as the COVID-19 pandemic continues to recede into the national memory—evidenced by the recent culmination of the national emergency
On March 3, the Criminal Division of the Department of Justice announced a two-part pilot program to encourage corporations to implement compliance programs with provisions for employee compensation incentives and clawbacks designed to prevent corporate crime. Last week, at the American Bar Association’s 38th Annual National Institute on White Collar Crime, Deputy Attorney General
On February 22, 2023 the Department of Justice (DOJ) released a new policy governing self-disclosure of corporate criminal wrongdoing to United States Attorney’s Offices (USAOs). The policy entitled “United States Attorney’s Office Voluntary Self-Disclosure Policy” (the “VSD Policy”) is the latest guidance from the department designed to encourage businesses to report and remediate
Earlier this month, DOJ updated its Corporate Enforcement Policy (CEP). Aimed at encouraging companies to voluntarily disclose unlawful conduct, the updated CEP gives greater opportunities to companies to avoid charges altogether or to get more cooperation credit.
On January 17, 2023, DOJ announced what Assistant Attorney General Kenneth
The U.S. Department of Justice is eyeing new guidance for how prosecutors should assess employee compensation packages when determining whether a company’s compliance efforts warrant favorable treatment in the resolution of criminal investigations.
Acting Principal Deputy Assistant Attorney General Nicole Argentieri said Thursday that the Criminal Division is considering new guidance that would help companies