Investigations, Enforcement, & Compliance Alerts

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May 20, 2025

10 min read

Rebalancing the Sticks and the Carrots? A New DOJ White-Collar Enforcement Plan

Given the recent changes the Trump Administration has made at the Department of Justice (DOJ),many people have wondered when a formal change to the
DOJ’s white-collar prosecution policies, particularly the corporate self-disclosure policy, might come. During remarks at a Financial Crimes Conference on May
12, Matthew Galeotti, the new Head of the DOJ’s Criminal Division, announced some of the changes to the DOJ’s policies, starting with the new c...Read more...Read more

May 1, 2025

15 min read

Future FCA Enforcement Expectations in Light of New Administration Priorities and 2024 Recoveries

The annual False Claims Act (FCA) recovery statistics issued by the U.S. Department of Justice for Fiscal Year 2024, coupled with the Trump administration’s
focus on the elimination of waste, fraud, and abuse in government spending and apparent intentions to rely on the FCA to pursue other administration
priorities, signal a likely increase in FCA investigations and actions throughout 2025 and beyond....Read more

March 20, 2025

13 min read

Fourth Circuit Allows Immediate Enforcement of DEI Executive Orders: Implications for Federal Contractors and Grant Recipients

On March 14, 2025, in a late Friday decision, a panel of judges from the U.S. Court of Appeals for the Fourth Circuit ruled that, for the time being, the Trump
Administration is permitted to enforce Executive Orders (EOs) 14151 (Ending Radical and Wasteful Government DEI Programs and Preferencing) and 14173
(Ending Illegal Discrimination and Restoring Merit-Based Opportunity), which prohibit Diversity, Equity, and Inclusion (DEI) (also referred to as Div...Read more...Read more

January 31, 2025

10 min read

Understanding and Addressing Increased FCA Exposure Risks Resulting from DEI-Focused Executive Order

On January 21, 2025, President Trump issued a sweeping executive order titled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” (EO).
The EO targets diversity, equity, inclusion, and accessibility (DEI) programs in the public and the private sectors. The EO signals that organizations receiving
federal funds, whether through government contracts or otherwise, may be liable under the False Claims Act (FCA)—one of the government’s m...Read more...Read more

October 24, 2024

4 min read

DOJ Civil Cyber-Fraud Initiative Continues to Impact Government Contractors – The Latest False Claims Act Settlement

On October 22, 2024, the Department of Justice announced a False Claims Act (FCA) settlement related to a government contractor’s failure to adhere to
certain cybersecurity requirements. Specifically, Pennsylvania State University (Penn State) has agreed to pay US$1.25M to resolve allegations that it violated
the FCA by failing to comply with cybersecurity requirements in fifteen contracts or subcontracts involving the Department of Defense (DOD) or t...Read more...Read more

July 15, 2024

3 min read

The Supreme Court’s Recent Rulings—A Boon for Government Contractors?

The Supreme Court of the United States’ recent decisions in Loper Bright Enterprises et al. v. Raimondo, 603 U.S. (2024) and Corner Post v. Board of
Governors, Federal Reserve System, 603 U.S. __ (2024), may provide federal contractors with new arguments and opportunities to challenge agency
regulations in litigation and bid protests....Read more

April 8, 2024

13 min read

2023 DOJ FCA Enforcement: Expectations for Future

On Feb. 22, 2024, the US Department of Justice (DOJ) released its annual False Claims Act (FCA) recovery statistics and announced that it obtained more than
$2.68 billion in settlements and judgments in fiscal year (FY) 2023 from civil cases involving fraud and false claims against the government, a 21% increase
over the prior year’s recoveries. As such, FY 2023 was another strong year for FCA enforcement and marked the fifteenth straight year where re...Read more...Read more

March 14, 2024

8 min read

Come See Us Before We Come See You – DOJ Announces New Whistleblower Program Intensifying Corporate Enforcement Efforts

The Department of Justice is intensifying its corporate enforcement efforts with a new whistleblower program. DOJ has made it clear that corporations and
individuals with knowledge of corporate misconduct should “come see us before we come see you.”...Read more

February 9, 2022

14 min read

The Announcement of the DOJ’s Near-Record-Breaking 2021 FCA Recoveries Provides Valuable Guidance on What to Expect in the Coming Years

On February 1, 2022, the U.S. Department of Justice (“DOJ”) released its annual False Claims Act (“FCA”) recovery statistics and announced that it had
obtained more than $5.6 billion in settlements and judgments in fiscal year 2021 from civil cases involving fraud and false claims against the government.
This total—which was driven by record-breaking recoveries in the health care industry, a traditional leading area for FCA recoveries—is more tha...Read more...Read more

About This Blog

Winston & Strawn’s Investigations, Enforcement, & Compliance Alerts highlight and analyze significant issues and developments in government investigations, enforcement, civil and criminal trial defense and litigation, compliance, and related matters, providing insights on the legal and strategic implications for individuals and corporations conducting domestic and international business.