DOJ Announces Civil Rights Fraud Initiative: Department Will Seek To Use The False Claims Act To Enforce Civil Rights Laws Against Universities And Government Contractors

by Debo P. Adegbile, Christopher Babbitt, Brian Boynton, Lisa Brown, Kevin Lamb, and Brenda E. Lee

Photos of authors

Top left to right: Debo P. Adegibile, Christopher Babbitt, Brian Boynton, Lisa Brown, Kevin Lamb, Brenda E. Lee (photos courtesy of Wilmer Cutler Pickering Hale and Dorr LLP)

On May 19, 2025, Deputy Attorney General Todd Blanche announced a new Civil Rights Fraud Initiative within the Department of Justice to “utilize the False Claims Act to investigate and, as appropriate, pursue claims against any recipient of federal funds that knowingly violates federal civil rights laws.” 

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New Orders Lifting Bars Signal Shift by SEC

by Joel M. Cohen, Ladan Stewart, and Robert DeNault

Photos of the authors

Left to right: Joel M. Cohen, Ladan Stewart, and Robert DeNault (photos courtesy of White & Case LLP)

In recent months, the U.S. Securities and Exchange Commission has signaled a shift in its approach to applications to lift administrative bars that restrict participation in the securities industry.  This suggests there is presently a window of opportunity for individuals subject to temporary or permanent bars to seek relief from the Commission.  Along the same lines, we expect the Commission to be more open to applications for waivers from statutory disqualifications triggered by many SEC orders.

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A Step Towards Transparency Or The Devil Is In The Detail? Analysing The Effectiveness Of The SFO’s New Corporate Guidance

by Jonah Anderson, Neill Blundell, Anneka Randhawa, and Phil Taylor

Photos of the authors

From left to right: Jonah Anderson, Neill Blundell, Anneka Randhawa and Phil Taylor (photos courtesy of White & Case LLP)

More than a decade ago, the concept of the Deferred Prosecution Agreement (DPA) became part of UK law. Ever since, there has been considerable uncertainty as to exactly what conditions a company needs to meet in order to be given the chance to enter into a DPA. Continue reading →

White Collar Experts Discuss New DOJ Criminal Enforcement Priorities (Part II)

Editor’s Note: PCCE has been following the Trump Administration’s new approach to corporate criminal enforcement. In this post, which is the second in a 2-part series, PCCE invited leading white collar practitioners to discuss the new enforcement priorities and revisions to the DOJ Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) outlined by Matthew Galeotti, Head of the Criminal Division for the DOJ, in a speech at the SIFMA Anti-Money Laundering and Financial Crimes Conference on May 12, 2025.

Photos of the authors

Left to right: Robertson Park, Elizabeth Roper, and Maria Piontkovska (photos courtesy of the authors)

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Retheorizing Compliance: Moving from Defense to Offense in Uncertain Times

by Todd Haugh and Suneal Bedi

Left to right: Todd Haugh and Suneal Bedi (photos courtesy of the authors)

The Trump administration—Trump 2.0, as some are calling it—is moving at unprecedented speeds to remake how government regulates business. In the administration’s first 100 days alone budgets and personnel have been downsized at the IRS, EPA, CFPB, and FTC, among other agencies. Enforcement of the FCPA has been paused, more than a dozen inspector generals have been removed from their posts, and the newly confirmed Attorney General and FBI Director are expected to work in tandem to drastically refocus civil and criminal enforcement.   

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Five Tips to Strengthen Trade Secret Damages

by Manuel J. Velez

Photo courtesy of Mayer Brown LLP

Trade secret litigation can be complex and challenging, especially when it comes to securing appropriate damages. To maximize your chances of obtaining a favorable outcome, consider these five essential tips:

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White Collar Experts Discuss New DOJ Criminal Enforcement Priorities (Part I)

Editor’s Note: PCCE has been following the Trump Administration’s new approach to corporate criminal enforcement. In this post, PCCE invited leading white collar practitioners to discuss the new enforcement priorities and revisions to the DOJ Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) outlined by Matthew Galeotti, Head of the Criminal Division for the DOJ, in a speech at the SIFMA Anti-Money Laundering and Financial Crimes Conference on May 12, 2025.

Photos of the authors

Top left to right: Paul Krieger, Michael Chang-Frieden, Sharon Cohen Levin, and Andrew J. DeFilippis
Bottom left to right: David Massey, Jamie Schafer, Seetha Ramachandran, and William C. Komaroff
(photos courtesy of the authors)

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The Fallout from SEC v. Jarkesy: Is There a Right to a Jury Trial in Administrative Enforcement Actions Brought by NYDFS?

by Matthew L. Levine

Photo of the author

Photo courtesy of author

Legal developments emerging in the wake of the Supreme Court’s decision in SEC v. Jarkesy, 603 U.S. 109 (2024), present an important question for entities licensed by the New York State Department of Financial Services (NYDFS):  in an administrative enforcement action brought by NYDFS, does Jarkesy entitle the targeted entity to a jury trial?

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UK Serious Fraud Office Issues New Self-Reporting and Corporate Cooperation Guidance

by Lloyd Firth and Frederick Saugman

Left to right: Lloyd Firth and Frederick Saugman (photos courtesy of Wilmer Cutler Pickering Hale and Dorr LLP)

On 24 April 2025, the UK Serious Fraud Office (SFO) issued new guidance to encourage companies to self-report suspected corporate wrongdoing. The guidance states that self-reporting, combined with full cooperation with the SFO’s investigation will, absent exceptional circumstances, lead to the SFO inviting the company to commence Deferred Prosecution Agreement (DPA) negotiations.[1] While the guidance is a welcome recognition that companies crave certainty of outcome in their dealings with the SFO and a sign of the agency’s increased pragmatism, in practice it is unlikely to move the needle for companies on notice of suspected wrongdoing facing the critical strategic decision of whether and when to self-report.

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