We are pleased to announce a new, quarterly podcast series:  “The Inspector General.”  Hosted by former State Department and Homeland Security Department Inspector General and partner in our Government Investigations and White Collar practice, Clark Ervin, the podcast is intended especially for government contractors and grantees, who can be the subject of…

While the United States has announced a pause on Foreign Corrupt Practices Act enforcement, the rest of the world is increasing its focus on prosecuting corrupt activities. This is a reminder to companies with a global footprint, including those headquartered in the U.S. that may not have physical operations overseas, that foreign activities likely fall…

The European Commission’s (EC) recent announcement of the Omnibus Simplification Proposals signals that it has heard the challenges and objections raised by companies affected by the new requirements of the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD). But in the US, Senator Bill Hagerty (R-TN), a member of the Senate…

Last month, the UK’s Office of Financial Sanctions Implementation’s (“OFSI”) published a Threat Assessment analyzing sanctions compliance involving UK financial services firms since February 2022, when Russia invaded Ukraine.

In the first of our two-part article (available here), we summarized the six key areas of risk that OFSI identified in its Threat Assessment.

In…

In February 2025, the UK’s Office of Financial Sanctions Implementation (“OFSI”) issued a report outlining its assessment of the sanctions-related threats posed to the UK by firms operating in the UK’s financial services sector.  As to be expected, the report focuses on the risks associated with transactions since February 24, 2022, when Russia invaded Ukraine…

Multi-defendant criminal investigations present a classic prisoner’s dilemma.  The parties would benefit from cooperating with one another but are incented to become adversaries, most often due to a lack of information sharing and resultant lack of trust and transparency.  Fortunately, the law provides a tool:  the common-interest privilege, which enables parties to share information in…

The start of a new year presents an opportune time to reflect on the past.  We have been tracking and reporting on the U.S. Department of Justice (“DOJ”)’s Civil Cyber-Fraud Initiative (“CCF Initiative”), which former U.S. Deputy Attorney General Lisa O. Monaco announced in October 2021. The CCF Initiative employs the powerful False Claims Act…