Investigations & Enforcement

The European Union’s Anticorruption Directive 2026/1021, effective June 1, 2026, mandates Member States to implement measures combating corruption. The Directive requires Member States to adopt nine anticorruption laws, establish corporate liability, impose significant penalties, and adopt extraterritorial jurisdiction.

On May 19, 2025, the U.S. Department of Justice (“DOJ”) announced the launch of its Civil Rights Fraud Initiative, a new enforcement effort focused on identifying and addressing false certifications of compliance with civil rights laws by recipients of federal funds.

The Division of Enforcement (Division) of the U.S. Commodity Futures Trading Commission (CFTC) recently updated its policy on cooperation to provide greater clarity and consistency and to align more closely with the Department of Justice’s Corporate Enforcement and Voluntary Self-Disclosure Policy.

Investigations & EnforcementThe European Union’s Anticorruption Directive 2026/1021, effective June 1, 2026, mandates Member States to implement measures combating corruption. […]

The Department of Justice (DOJ) announced the FOCUS Initiative to enhance its relationships with data miners who use data analytics to detect fraud in publicly available data. This initiative aims to prioritize collaboration with reliable data miners and direct resources to cases with a high probability of recovery. Companies exposed to potential FCA claims should proactively scrutinize their data and consider leveraging AI models to assess risks and build defensive narratives.

On April 10, 2025, the Department of Justice (DOJ) resolved False Claims Act (FCA) claims arising out of a federal contractor’s implementation of a diversity, equity, and inclusion (DEI) program.

On March 10, 2026, the Department of Justice (DOJ) released a DOJ-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) applicable to all criminal matters, except antitrust. The policy is intended to ‘promot[e] uniformity, predictability, and fairness in how [the federal government] pursues white-collar cases.’

Investigations & EnforcementThe European Union’s Anticorruption Directive 2026/1021, effective June 1, 2026, mandates Member States to implement measures combating corruption. […]

The DOJ recently announced that in FY25 it collected more than $6.8 billion in FCA settlements and judgments, raising the government’s civil FCA recoveries since enactment to $85 billion. Of the $6.8 billion collected in FY25, $5.3 billion came through qui tam suits. Some companies mitigated their FCA exposure by making qualifying self-disclosures to the government. (See full DOJ press release and fact sheet.)