On June 18, the U.S. Justice Department (“DOJ”) announced the results of a nationwide sweep conducted by the Medicare Fraud Strike Force which led to the arrest of more than 240 healthcare providers alleged to be involved in over $700 million in false billings for Medicare services.  Earlier in the…

In February, yet another high-profile negotiated settlement between a company and a government agency was thrown into doubt after a judge refused to approve the terms reached by the parties. On Feb. 5, U.S. District Court for the District of Columbia Judge Richard Leon refused to approve a motion filed…

Currency of information: Spring 2014 The U.S. Sentencing Guidelines (“Guidelines”) play an important, and often misunderstood, role in the final resolution of Foreign Corrupt Practices Act (“FCPA”) investigations involving the U.S. Justice Department (“DOJ”).  Those unfamiliar with the Guidelines often make two opposite, but equally significant, mistakes in interpreting them.…

The days of the US Justice Department being the sole prosecutor of international corporate corruption are long gone. Recent news reports are replete with anti-corruption enforcement actions by agencies in China, Brazil, Italy and elsewhere. Academic research also suggests that DOJ enforcement actions against a country’s nationals frequently leads to…