Category: DOJ Updates
Department of Justice Updates Guidance on Evaluation of Corporate Compliance Programs
On June 1, the DOJ updated its guidance for evaluating a company’s compliance program when resolving corporate investigations. The updated guidance makes clear that prosecutors should consider a company’s particular circumstances when evaluating its compliance program. The updated guidance also emphasizes that a company must be proactive and continually assess […]
House Select Subcommittee Announces First Public Investigations Involving CARES Act
As anticipated, the hundreds of billions of dollars allocated under the CARES Act Paycheck Protection Program have become the focus of scrutiny from investigators. On May 8, the House Select Subcommittee on the Coronavirus Crisis launched its first public broadsides at five companies that received PPP loans.
What You Need to Know About Potential Exposure if You’ve Gotten a CARES Act Loan
We have previously looked at the many ways CARES Act funding can provide critical sources of money for both small and large businesses. We also have described the oversight bodies created by the CARES Act to police the use of disbursed funds. For many businesses, small or large, this may be the first […]
Multiple Layers of Oversight in the CARES Act: The Appetite for Accountability Will Long Outlast the Current Crisis
The estimated $2+ trillion stimulus bill – the Coronavirus Aid, Relief and Economic Security Act (CARES Act) – is meant to address the economic crisis caused by the coronavirus pandemic. The act will pump hundreds of billions of dollars into private sector businesses. But the money will come with new […]
Remaining Vigilant to Compliance and Enforcement Concerns in Times of Crisis
In times of increased financial stress—and particularly during times of financial shock where expectations and reality diverge significantly and rapidly—internal and external pressures can lead to risk-taking with lasting consequences. For example, pressure often mounts to boost revenue to save a failing quarter, to take advantage of government bailout opportunities, […]