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Case Summary In Kousisis v. United States , the Supreme Court addressed whether a defendant can be convicted under the federal wire fraud statute without causing the victim a net pecuniary loss. The case involved Stamatios Kousisis (“Kousisis”) and the industrial painting company he helped manage...

A Significant Shift in White Collar Criminal Enforcement The Department of Justice (“DOJ”) has unveiled a comprehensive plan for its white-collar crime enforcement strategy, laying out the “high-impact” areas where enforcement will be focused, changes and clarification of how the DOJ will view...

On May 19, 2025, the U.S. Department of Justice (“DOJ”) issued a memorandum and accompanying press release announcing its “Civil Rights Fraud Initiative,” designed to vigorously enforce the federal False Claims Act (“FCA”) “against those who defraud the United States by taking its money while...

The recent announcements in three U.S. Department of Justice (“DOJ”) national security prosecutions offer an early glimpse into some of the Trump Justice Department’s enforcement priorities. Indeed, these actions are consistent with the announced priorities of Attorney General Pamela Bondi, as set...

In a striking move at the end of March, the U.S. Department of Justice (“DOJ”) announced a $4.6 million settlement with MORSE Corp Inc. (“MORSE”), a defense contractor based in Cambridge, Massachusetts, for falsely certifying that the company complied with cybersecurity requirements. The...

On February 25, 2025, President Trump issued an Executive Order titled “Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information” (the 2025 Order). This directive is focused on significantly increasing governmental enforcement of price...

[Printable Version] Executive Summary We entered 2025 with the world in turmoil, a new American administration in the White House, and various global actors—friends and foes alike—still actively vying for the attention of the American public. The scene is set for a continued parade of foreign actors...

Over 8,000 stocks trade on American stock exchanges, [1] but billions of dollars in daily trades in these listed stocks and 12,000 more unlisted (non-exchange-traded) stocks occur outside of an exchange in Over-The-Counter ( “ OTC ” ) transactions. [2] A substantial portion of these trades involve...

Medical practices, dental practices and other health care entities must again comply with the federal Corporate Transparency Act (“CTA”). The deadline for compliance is March 21, 2025. What You Need to Know: The Corporate Transparency Act filing deadline is now March 21, 2025. Medical practices and...

What You Need to Know Attorney General Pam Bondi sets the tone with the issuance of 14 new Department of Justice memoranda on her first day on the job. Attorney General Pam Bondi’s memorandum on charging, pleas, and sentencing identifies the new administration’s key enforcement priorities, with some...

Introduction On December 20, 2024, the U.S. Department of Justice (DOJ) announced its long-awaited proposed amendments to the regulations adopted under the Foreign Agents Registration Act (FARA) in a Notice of Proposed Rulemaking (NPRM) submitted to the Federal Register. [1] FARA (the “FARA Statute...

The CTA madness continues. On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit (the "Fifth Circuit"), in the case of Texas Top Cop Shop v. Garland ("Texas Top Cop Shop"), stayed the enforcement of an injunction issued by the U.S. District Court for the Eastern District of Texas...

On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit (“Fifth Circuit”) granted the U.S. Government’s motion to stay the nationwide preliminary injunction issued by U.S. District Court for the Eastern District of Texas (“District Court”) on December 3, 2024, which temporarily halted...

The U.S. Supreme Court recently heard arguments in Wisconsin Bell, Inc. v. United States ex rel. Todd Heath , Docket No. 23-1127, a case in which the Court agreed to review whether reimbursement requests submitted to the Federal Communications Commission’s (FCC) “E-Rate Program” are considered...

The decision of the Federal District Court for the Northern District of Alabama in the case of National Small Business United v. Yellen , announced on Friday, March 1, 2024, has created uncertainty for both reporting companies and their attorneys under the Corporate Transparency Act (“CTA”). What...

For all “reporting companies” created or registered on or after January 1, 2024, information concerning the “beneficial owners” of the reporting company must be reported to the Financial Crimes Enforcement Network (“FinCEN”) along with information concerning “company applicants.” As a result, both...

On November 21, 2023, the Federal Trade Commission (FTC) approved a resolution allowing it to use “compulsory process in nonpublic investigations involving certain products and services that use or claim to be produced using artificial intelligence (AI) or claim to detect its use.” This allows the...

“Company applicants” — the term may sound vague, but the identities of “company applicants” of reporting companies are just as important under the new federal Corporate Transparency Act (the “CTA”) as the identities of the beneficial owners of those companies. What You Need to Know: The era of...

Beginning on January 1, 2024, the Corporate Transparency Act (the “CTA”) will require all “Reporting Companies” to report to the federal Financial Claims Enforcement Network (“FinCEN”) information about their “beneficial owners” and “company applicant’s (“BOI Reports”). The statutory definition of a...

On October 11, the U.S. Department of Justice released a settlement agreement with a large, Florida-based automotive management company for False Claims Act violations based on an allegedly improper forgiveness of a Paycheck Protection Program loan. Until now, the DOJ has primarily focused on...

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