Insights on Government Enforcement & White Collar

On July 8, the US Department of Justice’s (DOJ) Antitrust Division, in partnership with the United States Postal Service (USPS), announced the launch of a Whistleblower Rewards Program. This new initiative is designed to incentivize individuals to report violations of antitrust laws and crimes impacting USPS, its revenue, or its property.

The government has announced a renewed and expanded focus on False Claims Act (FCA) enforcement, doubling down on traditional health care priorities like kickbacks and drug pricing while signaling increased scrutiny of Electronic Health Records (EHR) manipulation.

ArentFox Schiff represented Robert DiMeo, former operations chief of Honor Finance Corp., in a case involving an alleged fraud scheme with losses exceeding $67 million.

Headlines that Matter for Companies and Executives in Regulated Industries

Welcome to the Summer 2025 issue of “FCA Enforcement & Compliance Digest,” our quarterly newsletter in which we compile essential updates on False Claims Act (FCA) enforcement trends, litigation, agency guidance, and compliance tips. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

On June 9, Deputy US Attorney General Todd Blanche issued a memorandum outlining new guidelines for the enforcement of the Foreign Corrupt Practices Act (FCPA).

Headlines that Matter for Companies and Executives in Regulated Industries

ArentFox Schiff is pleased to announce that 69 attorneys were recognized as leaders in their field and 23 practices spanning the firm’s litigation, regulatory, and transactional capabilities were ranked in the 2025 edition of Chambers USA: America’s Leading Lawyers for Business.

Headlines that Matter for Companies and Executives in Regulated Industries

Headlines that Matter for Companies and Executives in Regulated Industries

On May 9, President Trump issued a new Executive Order (EO) titled “Fighting Overcriminalization in Federal Regulations” to address criminal enforcement of regulatory offenses, particularly strict liability offenses where the offender need not have had a culpable state of mind to be convicted.

The US Department of Justice (DOJ) revised its Criminal Division Corporate Enforcement and Voluntary Disclosure Policy (CEP), outlining the benefits a company may earn by voluntarily self-disclosing misconduct, as well as the path to resolution in other cases. The DOJ aimed to simplify the document and clarify the outcomes that companies can expect.

Headlines that Matter for Companies and Executives in Regulated Industries

On May 12, Matthew R. Galeotti, the head of the US Department of Justice’s (DOJ) Criminal Division, announced a new white collar enforcement plan, outlined changes to the Corporate Enforcement and Voluntary Disclosure Policy, and added new priority areas to the Corporate Whistleblower Awards Pilot Program Policy. The DOJ also introduced a new corporate monitor selection policy.

ArentFox Schiff is pleased to announce that Partners Imron Aly and Maggie Hickey have been listed among Crain’s Chicago Business’ 2025 Notable Litigators.

Michelle J. Shapiro of ArentFox Schiff will be a panel moderator at the 2025 White-Collar Crime Conference hosted by the Boston Bar Association (BBA).

On April 7, the Deputy Attorney General (DAG) Todd Blanche issued a memorandum entitled “Ending Regulation By Prosecution,” detailing a significant shift in the US Department of Justice’s (DOJ) approach to digital assets.

On April 2, California Attorney General (AG) Rob Bonta issued an alert reminding businesses operating in California that it is illegal to violate the Foreign Corrupt Practices Act (FCPA).

On March 10, US District Judge Jed S. Rakoff of the Southern District of New York issued a decision in United States v. Tavberidze, holding that section 3E1.1(b) of the US Sentencing Guidelines, which provides a one-point reduction in offense level to defendants who promptly plead guilty, is an “unconstitutional penalty” that punishes defendants for exercising their constitutional right to a trial.

ArentFox Schiff attorneys William Ziegelmueller and Kaitlin Klamann attended the American Bar Association’s (ABA) 40th White Collar Crime Institute (WCCI) March 5-7, 2025, in Miami, Florida.

Headlines that Matter for Companies and Executives in Regulated Industries

With 2025 underway, the ArentFox Schiff White Collar team highlights the US Department of Justice’s (DOJ) new enforcement priorities and two cases pending before the US Supreme Court that could have sweeping implications for future white-collar fraud cases.

Partner Alexander Birkhold was quoted in a recent discussion on the effectiveness of “click-through training,” referring to trainings using click-through screens and multiple-choice tests, in corporate compliance training.

Last week, Attorney General Pamela Bondi issued 14 memoranda outlining new enforcement priorities at the US Department of Justice (DOJ). Notably, DOJ resources will shift away from the Foreign Corrupt Practices Act (FCPA) and the Foreign Agents Registration Act (FARA) and toward prosecuting human trafficking and smuggling, immigration enforcement, and pursuing total elimination of cartels and transnational criminal organizations.

ArentFox Schiff is pleased to announce the election of 15 new partners, effective January 1, 2025.