David E. Carney

David E. Carney brings more than two decades of experience representing individuals and companies in high-stakes government enforcement matters, internal investigations, complex civil litigation, and compliance program design. His practice is defined by strategic problem-solving, disciplined advocacy before regulators, and a pragmatic approach to mitigating risk while protecting business objectives.

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.

David E. CarneyDavid E. Carney brings more than two decades of experience representing individuals and companies in high-stakes government enforcement […]

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.’

David E. CarneyDavid E. Carney brings more than two decades of experience representing individuals and companies in high-stakes government enforcement […]

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.)