DOJ Grants First Healthcare Declination Under New Corporate Enforcement Policy While Indicting Founder
On July 29, 2026, the Department of Justice (“DOJ”) announced that, consistent with Part I of DOJ’s Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”), it declined to prosecute Campus Eye Management Holdings LLC and its wholly owned subsidiary, Campus Eye Management LLC (collectively, “Campus Eye”), a management services organization that provided billing and other services to an optometry practice and ambulatory surgery center. DOJ had been investigating Campus Eye for alleged healthcare fraud, including illegal kickbacks. This is the first declination involving a healthcare company under the new, Department-wide CEP. And it is only the second healthcare fraud declination under any voluntary self-disclosure policy in DOJ history—the first being the HealthSun Health Plans, Inc. matter handled by the same team (i.e., the Health Care Fraud Unit) when they were part of the Criminal Division’s Fraud Section, prior to creation of the National Fraud Enforcement Division (“NFED”) earlier this year. Click here to read the full blog post.
DOJ Expands Trade Fraud Enforcement After $1 Billion Milestone
The U.S. Department of Justice and the Department of Homeland Security announced on July 14, 2026, that the Trade Fraud Task Force had surpassed $1 billion in criminal and civil recoveries, penalties, forfeitures, and publicly charged losses less than one year after its launch. The announcement confirms a fundamental shift in the federal government’s approach to customs and trade enforcement, reflecting increased emphasis on rigorous criminal prosecution and civil enforcement under the False Claims Act.
DOJ Ends 15-Year-Old Economic Espionage Case—With Prejudice
In a surprising development, on July 13, 2026, the U.S. Department of Justice dismissed with prejudice its landmark economic espionage prosecution against Pangang Group Company, Ltd. and its subsidiaries—a Chinese state-owned enterprise accused of stealing DuPont trade secrets for the benefit of the Chinese government. The dismissal came just one week after trial began, bringing to an end one of the longest-running and most consequential prosecutions under the Economic Espionage Act.
Although the case itself is over, its legal legacy remains. Over more than a decade of litigation, the prosecution produced significant rulings on service of process, foreign sovereign immunity, and the treatment of foreign state-owned enterprises under the Economic Espionage Act and the Foreign Sovereign Immunities Act. Those decisions, together with amendments to Federal Rule of Criminal Procedure 4 prompted by the litigation, will continue to shape future prosecutions.
DOJ’s 2026 Health Care Fraud Takedown Highlights Increased Coordination and Data-Driven Enforcement
This week, DOJ announced the results of its 2026 National Health Care Fraud Takedown, which involved charges against 455 defendants, including 90 medical professionals, in connection with alleged schemes involving more than $6.5 billion in false claims submitted to Medicare, Medicaid, and other federal health care programs. The Takedown involved the participation of 50 state Medicaid Fraud Control Units and included cases in 56 federal districts and 45 U.S. states and territories.
June Antitrust and Competition Bulletin: Top-of-Mind Global Antitrust Issues
Recent antitrust developments offer important insights into evolving enforcement priorities on both sides of the Atlantic. This month’s roundup examines the appointment of Stanley Woodward to assume authority to act as Assistant Attorney General for the DOJ Antitrust Division, a leadership change that could influence the Division’s enforcement approach and decision making in the near term. The post also discusses the European Commission’s continued scrutiny of coordination among competitors through minority shareholdings, signaling ongoing concern with information sharing, governance rights, and other conduct that may facilitate anti-competitive behavior.
The update further explores the FTC’s views on merger remedies, recent healthcare merger enforcement actions, and growing regulatory attention to modern pricing practices. Read the full post for key takeaways on the latest antitrust enforcement trends and the compliance considerations they present for businesses.
DOJ Reaches $507,144 Settlement with Defense Contractor, Signals Increased FCA Scrutiny of Cybersecurity Self-Assessments
On June 18, 2026, DOJ announced a settlement with LOGZONE Inc., a defense contractor, to pay $507,144 to resolve allegations that it violated the False Claims Act through its failure to satisfy cybersecurity requirements in its contracts with the Department of the Navy (“the Navy”). This settlement involves yet another coordinated enforcement effort through the recently created Task Force to Eliminate Fraud, previously reported on here and here. DOJ reached this settlement with assistance from the Department of the Navy, the Department of the Army, and the Defense Contract Management Agency (“DCMA”). This settlement underscores cybersecurity compliance as a focus of FCA enforcement.
Supreme Court Limits Enforcement of Appellate Waivers in Cases Involving Miscarriages of Justice
On June 18, 2026, the U.S. Supreme Court held in Hunter v. United States that appellate waivers in plea agreements are not enforceable when doing so would result in a “miscarriage of justice.” The Court rejected arguments that knowing and voluntary appeal waivers must always be enforced, recognizing instead a narrow exception for sentences tainted by obvious and egregious errors that threaten public confidence in the judiciary.
The decision resolves a longstanding circuit split and underscores the judiciary’s independent role in safeguarding the integrity of the criminal justice system. Although appellate waivers remain generally enforceable, Hunter creates a limited pathway for defendants to challenge certain unlawful sentences notwithstanding a waiver provision in a plea agreement.
The case also produced a notable concurrence from Justice Gorsuch, joined by Justices Sotomayor and Jackson, questioning the modern plea-bargaining system and the leverage prosecutors wield in securing guilty pleas and appellate waivers. Read more in this blog post.
Cracking Open the Grand Jury Black Box: Recent Cases Show Prosecutorial Misconduct Can Lead to Dismissal of Charges
Recent federal cases in Wyoming and Illinois involving judicial findings of prosecutorial misconduct before the grand jury have resulted in dismissed indictments. In Wyoming, three federal judges dismissed nine felony indictments after concluding that the interim U.S. Attorney made inflammatory and prejudicial remarks to grand jurors that compromised the integrity of the proceedings. In Illinois, the prosecution of the so-called “Broadview Six” collapsed after a federal judge authorized disclosure and review of grand jury materials amid allegations of serious misconduct during the charging process, leading the government to dismiss the remaining charges with prejudice.
These outcomes are remarkable because courts rarely agree to scrutinize what occurs before the grand jury. Grand jury proceedings are cloaked in secrecy, and courts generally presume that prosecutors properly present evidence and accurately instruct grand jurors on the law. As a result, efforts to challenge indictments based on misconduct in the charging process face a steep uphill battle. The Wyoming and Illinois cases nevertheless demonstrate that, where defense counsel can identify objective facts raising legitimate concerns about the integrity of the grand jury process, courts may be willing to look behind the curtain, authorize disclosure or review of grand jury materials, and, in extraordinary circumstances, dismiss indictments altogether. This blog post examines those cases, the legal framework governing grand jury secrecy, and the practical lessons they offer for defense counsel seeking to investigate and litigate potential grand jury misconduct.
