Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Eric Olshan

Photo of Eric Olshan Eric Olshan, a former United States Attorney and veteran federal prosecutor, helps clients navigate complex government investigations, enforcement actions, and high-stakes litigation. With nearly two decades of white collar experience, Eric brings a deep understanding of how complex cases are built—and how they can be resolved successfully. He is uniquely situated to advise clients in times of crisis and in a broad range of matters involving corporate and financial fraud, cyber and data security, national security, health care enforcement, and environmental regulation.

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After a Pause, DOJ’s Updated FCPA Guidelines Focus on Cartels and TCOs, But Corporate Exposure Remains

Anti-Bribery and Corruption
Executive Summary: On June 9, Deputy Attorney General Todd Blanche issued a memorandum to the Department of Justice’s Criminal Division, outlining the Department’s focus for pending and future FCPA actions.  A day later, Matthew Galeotti, the Head of the Criminal Division, offered more insight into how this administration will approach FCPA investigations and enforcement actions. … Continue Reading

Order Limiting Strict Liability Has Implications on FDCA Enforcement for Companies, Individuals

Enforcement and Prosecution Policy and Trends, Fraud, Deception and False Claims
On May 9, 2025, President Trump signed an Executive Order titled “Fighting Overcriminalization in Federal Regulations.” The Order seeks to reduce the regulatory burden on Americans and prevent individuals from being criminally penalized for unknowingly violating complex regulations.  In pursuit of these goals, the Order sets forth a policy “generally disfavor[ing]” strict liability crimes.  Agencies… Continue Reading

The Risks of Rushing In: A Closer Look at DOJ Criminal Division’s Updated Corporate Enforcement Policy in the Broader Enforcement Landscape

Fraud, Deception and False Claims
I. Introduction: More Clarity, But Not a Complete Roadmap On June 10, Matthew Galeotti, the Head of the U.S. Department of Justice’s (DOJ) Criminal Division, delivered remarks at an event hosted by the American Conference Institute,[1] in which he discussed recent updates to the division’s Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP).[2] The revisions mark… Continue Reading

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