Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Justin Givens

Photo of Justin Givens Justin Givens, a former federal prosecutor, is a member of the firm’s Government Investigations and White Collar Litigation Department. Justin is a skilled trial attorney with over a decade of experience leading sensitive, high-profile internal investigations. He represents corporations, financial institutions, and executives facing legal and reputational risk in criminal, regulatory, and civil proceedings.

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

By Eric Olshan, Patrick Rowan, Justin Givens, Roy Dixon III, Garen S. Marshall, Stephen Weiss, Ryan Buchanan, Alex J. Brackett, Michael F. Easley, Jr., Steven McCool, Elissa Baur, Jason H. Cowley, Caroline Schmidt Burton, V. Kathleen Dougherty and Joie Johnston on 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

Justice Department Issues First Declination Under NSD’s M&A Safe Harbor Policy to Private Equity Firm, Reinforcing Roadmap for Acquiring Firms

By Garen S. Marshall, Justin Givens, Mindy Sauter and Alex J. Brackett on Anti-Bribery and Corruption
On June 16, the U.S. Department of Justice’s (DOJ) National Security Division (NSD) and the U.S. Attorney’s Office for the Southern District of Texas (USAO-SDTX) announced their decision to decline prosecution of White Deer Management LLC (White Deer), a private equity firm that voluntarily disclosed export control and sanctions violations committed by its newly acquired… Continue Reading

Healthcare Fraud Enforcement in a Second Trump Administration: Trends, Priorities, and Implications

By Mindy Sauter, Clint Narver, Michael Elliott, Garen S. Marshall, Justin Givens, Michael J. Podberesky and Rhea Shahane on Fraud, Deception and False Claims
On May 12, 2025, the United States Department of Justice’s (“DOJ”) Criminal Division released a major policy memorandum outlining its enforcement priorities for the upcoming year. Unsurprisingly, the number one priority for the Division was investigating and prosecuting white-collar crimes related to waste, fraud, and abuse—and particularly healthcare fraud. This emphasis on prosecuting healthcare fraud… Continue Reading

DOJ Signals Shift in White Collar Enforcement: New Policies Stress Proportionality, Partnership, and Clarity

By Garen S. Marshall, Justin Givens, Jason H. Cowley and Roy Dixon III on Anti-Money Laundering
In a major policy address delivered yesterday at the Security Industry and Financial Markets Association’s (SIFMA) Anti-Money Laundering and Financial Crimes Conference in Washington, D.C., Matthew Galeotti, Head of the U.S. Department of Justice’s (DOJ) Criminal Division, announced a significant shift in how DOJ approaches white collar enforcement. The changes reflect a broader recalibration toward… Continue Reading

Europe Steps Up as U.S. Pauses FCPA Enforcement: What Companies Need to Know About the New International Anti-Corruption Taskforce

By Justin Givens, Garen S. Marshall, Caroline Schmidt Burton, Francesca Titus and Joie Johnston on Anti-Bribery and Corruption
In a significant move signaling Europe’s growing autonomy in global anti-corruption enforcement, prosecutors from the United Kingdom, France, and Switzerland have formed a new cross-border alliance: the International Anti-Corruption Prosecutorial Taskforce. Announced on March 20, 2025 by the U.K.’s Serious Fraud Office (SFO), the taskforce is designed to deepen cooperation among these three countries on… Continue Reading

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

The Foreign Extortion Prevention Act: Another Tool to Fight Foreign Corruption

By Katherine Richardson, Jason H. Cowley, Justin Givens and McGuireWoods LLP on Anti-Bribery and Corruption
In recent years, the Biden Administration has been vocal that combatting foreign public corruption is a key pillar of its national security efforts.[1]  Consistent with those policy goals, on December 22, 2023, Congress passed the Foreign Extortion Prevention Act (FEPA), a long-awaited complement to the Foreign Corrupt Practices Act (FCPA).  Where the FCPA targets those… Continue Reading

DOJ Announces Safe Harbor Policy for Mergers and Acquisitions

By Jason H. Cowley, Justin Givens, Edwin O. Childs, J. Brent Justus, Holden Brooks, Amy Manning and McGuireWoods LLP on Compliance, Enforcement and Prosecution Policy and Trends
In the U.S. Department of Justice’s continuing efforts to incentivize voluntary disclosure of corporate misconduct, Deputy Attorney General Lisa Monaco announced the Criminal Division’s latest corporate self-disclosure policy this week, aimed at mergers and acquisitions specifically (remarks Here).  Pursuant to DOJ’s new Mergers and Acquisitions Safe Harbor Policy (the “Policy”), acquiring companies that promptly and… Continue Reading

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