Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Caroline Schmidt Burton

Photo of Caroline Schmidt Burton Caroline is an experienced litigator in McGuireWoods’ nationally-recognized Government Investigations and White Collar Group. She represents corporate and individual clients in a wide-variety of high-stakes situations, including government and internal investigations, regulatory enforcement actions, and litigation in state and federal courts.

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Practical Tips for Companies Following President Trump’s Pause on FCPA Enforcement

By Caroline Schmidt Burton, Justin Givens, Alex J. Brackett, V. Kathleen Dougherty, Eric Snyder, Jason H. Cowley, John S. Moran, Roy Dixon III and Elizabeth Peters on Anti-Bribery and Corruption
Since the President signed the February 10, 2025 Executive Order (Order) pausing enforcement of the Foreign Corrupt Practices Act (FCPA) (Client Alert: President Trump issues Executive Order “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security”), companies with cross-border business operations have likely faced questions from both internal and external stakeholders… Continue Reading

Major Shift on Foreign Corrupt Practices Act: Trump Signs EO Pausing Enforcement

By Caroline Schmidt Burton, Justin Givens, Alex J. Brackett, Eric Snyder, John S. Moran, Jason H. Cowley, Patrick A. Wallace and Joie Johnston on Anti-Bribery and Corruption
Last night, in a move with wide-ranging implications for American companies doing business abroad, President Trump issued an executive order (Order) temporarily halting enforcement of the Foreign Corrupt Practices Act (FCPA).  The Order directs Attorney General (AG) Pam Bondi to review guidelines and policies governing FCPA investigations and enforcement actions in the next 180 days,… Continue Reading

DOJ Announces “Pilot Program Regarding Compensation Incentives and Clawbacks” with Significant Ramifications for Corporations Facing Criminal Investigations

By John S. Moran, Brandon M. Santos, Casey Erin Lucier, Jeffrey M. Hanna, Caroline Schmidt Burton and McGuireWoods LLP on Enforcement and Prosecution Policy and Trends
The Department of Justice Criminal Division announced a “Pilot Program Regarding Compensation Incentives and Clawbacks” (the “Program”) this week with broad implications for corporations and their individual executives operating within the Department’s jurisdiction. During two keynote speeches delivered at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco (remarks… Continue Reading

New DOJ Guidance on Corporate Criminal Enforcement

By John Adams, John S. Moran, Caroline Schmidt Burton, Emily Erb Kelley and McGuireWoods LLP on Enforcement and Prosecution Policy and Trends
RELATED UPDATE: DOJ Announces “Pilot Program Regarding Compensation Incentives and Clawbacks” with Significant Ramifications for Corporations Facing Criminal Investigations (March 6, 2023) On Sept. 15, 2022, U.S. Deputy Attorney General Lisa Monaco announced important guidance and new actions from the U.S. Department of Justice (DOJ or the Department) on corporate criminal enforcement. Her remarks, delivered… Continue Reading

Supreme Court to Review When DOJ May Dismiss Relator Suits

By Jonathan Ellis, Nicholas J. Giles, Caroline Schmidt Burton and Joshua Wade on Fraud, Deception and False Claims
Last month, the Supreme Court granted certiorari in United States ex rel. Polansky v. Executive Health Resources, Inc., a case presenting the question whether the federal government forfeits the authority to dismiss False Claims Act (FCA) suits brought in its name if it first declines to intervene in them. Continue reading our commentary on The FCA Insider.… Continue Reading

Elizabeth Holmes of Theranos Found Guilty of Making False Representations to Investors

By John Adams, Michael J. Podberesky, Caroline Schmidt Burton, Elissa Baur, Emily Erb Kelley and McGuireWoods LLP on Fraud, Deception and False Claims
Elizabeth Holmes, founder of Theranos, was convicted of three counts of wire fraud and one count of conspiracy to commit wire fraud. The verdict follows a high-profile, fifteen-week trial in federal court in San Francisco.  Holmes was alleged to have defrauded investors, medical professionals, patients, and the public by exaggerating and making false statements about… Continue Reading

Return to the Yates Memo: Deputy Attorney General Announces Tougher Approach to White Collar Enforcement

By John Adams, Caroline Schmidt Burton, Elissa Baur and McGuireWoods LLP on Enforcement and Prosecution Policy and Trends
RELATED UPDATE: New DOJ Guidance on Corporate Criminal Enforcement (9/16/2022) On October 28th, Deputy Attorney General Lisa Monaco announced that the U.S. Department of Justice (DOJ or Department) is renewing its focus on white collar crime and enforcement, in remarks delivered during the American Bar Association’s 36th National Institute on White Collar Crime. Deputy Attorney… Continue Reading

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