Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

George J. Terwilliger III

Photo of George J. Terwilliger III George Terwilliger is co-head of the firm’s white collar practice and leads the firm’s Strategic Response and Crisis Management practice group. Having served as both a front line federal prosecutor and as Deputy Attorney General of the United States in a 15 year public service career, George offers wide-ranging experience in civil and criminal litigation, agency enforcement proceedings, and government and internal investigations spanning over 20 years in private practice. He also has advised government officials, Congress and private organizations on national security, homeland defense, terrorism, and other public policy and legal issues.

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New DOJ Guidance on Corporate Criminal Enforcement

By George J. Terwilliger III, John Adams, Benjamin A. O'Neil, John S. Moran, Caroline Schmidt Burton, Jah Akande and Emily Erb Kelley 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

Corporate Campaign Contributions Are a Crime, Independent Expenditures Legitimate: Sixth Circuit Explains the Difference

By George J. Terwilliger III, Simon Davidson, Michael Francisco and Todd R. Steggerda on Enforcement and Prosecution Policy and Trends, Government Contracts
The Sixth Circuit has upheld the felony conviction of a former state party chair for illegal campaign contributions by a corporation he owned, in a case that both serves as an important reminder of the prohibition on corporate contributions to federal campaigns and shows that the Justice Department may be stepping up criminal election law… Continue Reading

Key Lessons for Colleges and Universities from Operation Varsity Blues

By George J. Terwilliger III, Government Investigations Group and McGuireWoods LLP on Enforcement and Prosecution Policy and Trends, Fraud, Deception and False Claims
On March 12, 2019, the United States Attorney’s Office for the District of Massachusetts announced federal criminal charges in “Operation Varsity Blues,” the largest college admissions case ever prosecuted by the Department of Justice. Fifty people have been charged for their involvement in what prosecutors describe as a nationwide conspiracy to get the children of… Continue Reading

Expansion of FCPA “Pilot Program” is Good for Companies, but Heed the Fine Print

By George J. Terwilliger III on Anti-Bribery and Corruption
Deputy Attorney General Rod Rosenstein’s Nov. 29 announcement that the Department of Justice FCPA “Pilot Program” will be permanently expanded is good news for companies that repeatedly faced the dilemma of whether or not to investigate and disclose FCPA issues discovered internally. However, companies should be careful to read the fine print of the policy… Continue Reading

Addressing Adulterated Food Risk

By James Neale, Trent Taylor, Alex J. Brackett and George J. Terwilliger III on Enforcement and Prosecution Policy and Trends
As we enter 2016, adulterated food-related investigations are leading the headlines—and should be leading companies in the food and beverage industry to ask what they can do to prevent and prepare for a potential outbreak on their watch or in their supply chain. From ice cream to eggs, and melons to Mexican food, a recent… Continue Reading

Defining a Legitimate Scope for the Federalization of Business Crime

By George J. Terwilliger III and Government Investigations Group on Enforcement and Prosecution Policy and Trends
The Washington Times published an article titled “Defining a Legitimate Scope for the Federalization of Business Crime” by Washington partner George Terwilliger, assisted by Richmond associate Katherine Mims Crocker, about the proper role of federal policing and prosecutorial authority, and how it exceeds the limited role the U.S. Constitution prescribes for it.… Continue Reading

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