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Business Crimes Bulletin

Features

Navigating DOJ’s New White-Collar Playbook Image

Navigating DOJ’s New White-Collar Playbook

Randy Grossman & Kareem Salem & Sareen Armani

Key Risks for Government Contractors, Tech Companies and Healthcare EntitiesThe DOJ recently unveiled a series of policy updates that shifted the white-collar enforcement landscape. These updates — an emphasis on the False Claims Act, a shift away from the Foreign Corrupt Practices Act, and increased incentives for self-disclosure and whistleblowers — are poised to reshape how companies approach compliance.

Features

When Sanctions Fail: The Ovsiannikov Case and Why Enhanced Due Diligence Must Become a Compliance Standard Image

When Sanctions Fail: The Ovsiannikov Case and Why Enhanced Due Diligence Must Become a Compliance Standard

Matt Winlaw

As geopolitical tensions escalate and global sanctions regimes become more aggressive, the Ovsiannikov case serves as a stark warning: checkbox compliance is no longer sufficient. EDD must become the operational standard — not just in banking, but across every sector involved in high-risk transactions.

Features

New Whistleblower Rewards Program Includes Monetary Incentive Image

New Whistleblower Rewards Program Includes Monetary Incentive

Carl W. Hittinger & Jacqueline Romero & Tyson Y. Herrold

On July 8, 2025, the DOJ, the U.S. Postal Service (USPS) and the USPS Office of Inspector General entered into a memorandum of understanding creating a whistleblower rewards program “to enable whistleblowers to report specific, credible and timely information about possible federal criminal violations.” The first of its kind, it creates a monetary incentive for whistleblowers to report criminal antitrust violations involving such conduct as price fixing, bid rigging, market allocation and even certain types of predatory conduct by monopolists.

Features

Foreign Sovereign Immunity May Be Obstacle to DOJ Enforcement Efforts Image

Foreign Sovereign Immunity May Be Obstacle to DOJ Enforcement Efforts

Andrew St. Laurent & Joseph DeBlasi

In May, Matthew R. Galeotti, Head of the Criminal Division of the Department of Justice, issued a department-wide memorandum setting forth the department’s enforcement priorities in the white-collar crime sphere. In it, the department announced an effort to combat crime that “poses a significant threat to U.S. interests,” including the “enabling of shadow-banking and sanctions evasions by hostile nation-states and terror regimes.” A potential obstacle to these enforcement efforts is the doctrine of foreign sovereign immunity. This doctrine, as its name suggests, has been used by courts to grant judicial immunity to foreign states, their instrumentalities, and their respective heads of state.

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