On August 5, the U.S. Securities and Exchange Commission (SEC) announced it is establishing the Financial Reporting and Accounting Unit (Unit) as a new unit within its Division of Enforcement. The Unit will be led by Timothy Zimmerman, who served as Deputy General Counsel of accounting firm RSM US following twelve years in private practice. It will focus on investigations of accounting and financial reporting fraud and general accounting and auditing misconduct. Establishing the Unit institutionalizes a priority area that both Chairman Paul Atkins and Enforcement Director David Woodcock highlighted in their prior public remarks.
https://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/06/AdobeStock_196632447.jpeg606833White Collar Watchhttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngWhite Collar Watch2026-08-07 10:58:522026-08-07 11:01:13New SEC Unit Signals Continued Focus on Accounting and Auditing Misconduct
On August 4, 2026, DOJ’s National Fraud Enforcement Division (“Fraud Division”) announced a significant expansion of its Northeast Health Care Fraud Strike Force into Philadelphia. The expansion will reunite the Fraud Division’s Health Care Fraud Section with the U.S. Attorney’s Office for the Eastern District of Pennsylvania; in 2018, the same teams launched what was then known as the Philadelphia-Newark Regional Strike Force, before reducing its operations to Newark-only in more recent years. Nationally, since its inception in 2007, the Health Care Fraud Strike Force program has been responsible for prosecuting more than 6,200 defendants who collectively billed federal health care programs and private insurers more than $45 billion.
http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.png00Lisa H. Millerhttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngLisa H. Miller2026-08-06 13:17:302026-08-06 13:17:30DOJ (Re-)Expands Northeast Health Care Fraud Strike Force to Philadelphia and Charges 19 Defendants in Medicaid Home Care Schemes
On July 30, 2026, the U.S. Department of Justice (DOJ) revised its Corporate Whistleblower Awards Pilot Program, expanding the pool of individuals who may qualify for an award. Most notably, DOJ eliminated the prior rule that automatically disqualified whistleblowers who could have been eligible for an award under another U.S. government whistleblower program, such as those administered by the SEC or CFTC. Instead, a whistleblower is now disqualified only if he or she actually receives an award from another program for reporting the same or substantially the same misconduct, while DOJ retains discretion to reduce or deny duplicative awards.
The revised guidance also includes several administrative updates, including confirmation that the program is now administered by the Criminal Division’s Money Laundering, Narcotics, and Forfeiture Section (formerly the Money Laundering and Asset Recovery Section) and that submissions will be made through a dedicated online intake portal. The covered subject-matter areas remain unchanged from the May 2025 expansion and continue to include, among other areas, financial institution crimes, bribery, healthcare fraud, trade and customs fraud, procurement fraud, immigration offenses, and sanctions-related misconduct.
For companies, the revisions further strengthen incentives for whistleblowers to report directly to DOJ, including in matters that may also be eligible for other agency whistleblower programs. At the same time, DOJ’s Corporate Enforcement and Voluntary Self-Disclosure Policy continues to provide a pathway to a declination for companies that promptly self-disclose, cooperate, and remediate misconduct, reinforcing the importance of effective internal reporting mechanisms and careful consideration of self-disclosure decisions in the face of potential whistleblower reports. Click here to read the full post.
http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.png00Kenneth A. Polite Jr.http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngKenneth A. Polite Jr.2026-08-03 14:43:462026-08-03 14:44:53DOJ Loosens the Whistleblower Program’s Bar on “Other Program” Claimants in Latest Revision
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.
https://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/07/General-Healthcare-Provider-6.jpg427600Jaime L.M. Joneshttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngJaime L.M. Jones2026-07-30 11:13:252026-07-30 11:20:05DOJ Grants First Healthcare Declination Under New Corporate Enforcement Policy While Indicting Founder
On July 23, 2026, the Department of Justice announced that clinical lab Magnolia Diagnostics and its owners agreed to pay $19.2 million to resolve allegations that they violated the False Claims Act by billing Medicare for medically unnecessary respiratory pathogen panel (“RPP”) testing performed in connection with COVID-19 testing at senior living communities. Notably, Magnolia’s investors separately agreed to pay an additional $4.8 million to resolve alleged common law claims for unjust enrichment and payment by mistake and claims under the Federal Debt Collection Procedures Act arising from distributions they received from the laboratory. Assistant Attorney General Brett Shumate emphasized that the Department will seek to hold accountable not only entities that submit false claims, but also individuals and investors who allegedly benefit from fraudulent conduct, which is consistent with previous statements of DOJ’s enforcement priorities and resolutions, as we covered here and here.
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.
http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.png00Kristin Graham Koehlerhttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngKristin Graham Koehler2026-07-24 09:15:202026-07-24 11:17:16DOJ Expands Trade Fraud Enforcement After $1 Billion Milestone
Antitrust enforcement continues to evolve on both sides of the Atlantic, with regulators sharpening their focus on consumer pricing, merger oversight, and national security review. The July 2026 edition of Sidley’s Antitrust and Competition Bulletin highlights several recent developments that signal where enforcement priorities may be headed.
This issue covers the DOJ and FTC’s call for state Attorneys General to investigate potential anticompetitive practices affecting gasoline prices, the Supreme Court’s decision in Trump v. Slaughter expanding presidential authority over FTC commissioners, the FTC’s $12 million HSR settlement, new guidance from the European Competition Network on merger call-in powers, and the EU’s adoption of updated foreign investment screening rules.
Click here to read the full bulletin for Sidley’s perspective on what these developments mean for businesses navigating antitrust compliance, M&A transactions, and an increasingly active global enforcement landscape.
https://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/07/MN-28679-Antitrust-and-Competition-Bulletin-Imagery-for-.com-blog.jpg332600White Collar Watchhttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngWhite Collar Watch2026-07-23 11:58:002026-07-23 11:58:00Sidley’s Antitrust and Competition Bulletin: U.S. and EU Authorities Signal Evolving Enforcement Priorities
On July 16, the Delaware Supreme Court held that defendants facing securities fraud and registration claims in administrative proceedings brought by the Delaware Investor Protection Unit are not entitled to a jury trial under the Delaware Constitution, distinguishing the U.S. Supreme Court’s decision in SEC v. Jarkesy. Applying its recently adopted Blue Beach Bungalows framework, the court concluded that the state statutory claims are not sufficiently analogous to common-law actions historically tried before a jury, despite the availability of monetary penalties.
The decision underscores that jury-trial challenges to state administrative enforcement actions will turn on the text and history of each state’s constitution and statutory scheme, rather than Jarkesy alone. With similar challenges pending in other jurisdictions, including Arizona, the ruling provides important guidance for regulators and litigants assessing the continued viability of administrative enforcement proceedings seeking civil penalties. Click here to read the full blog post.
New SEC Unit Signals Continued Focus on Accounting and Auditing Misconduct
On August 5, the U.S. Securities and Exchange Commission (SEC) announced it is establishing the Financial Reporting and Accounting Unit (Unit) as a new unit within its Division of Enforcement. The Unit will be led by Timothy Zimmerman, who served as Deputy General Counsel of accounting firm RSM US following twelve years in private practice. It will focus on investigations of accounting and financial reporting fraud and general accounting and auditing misconduct. Establishing the Unit institutionalizes a priority area that both Chairman Paul Atkins and Enforcement Director David Woodcock highlighted in their prior public remarks.
Read the full SEC press release here.
White Collar Watch
DOJ (Re-)Expands Northeast Health Care Fraud Strike Force to Philadelphia and Charges 19 Defendants in Medicaid Home Care Schemes
On August 4, 2026, DOJ’s National Fraud Enforcement Division (“Fraud Division”) announced a significant expansion of its Northeast Health Care Fraud Strike Force into Philadelphia. The expansion will reunite the Fraud Division’s Health Care Fraud Section with the U.S. Attorney’s Office for the Eastern District of Pennsylvania; in 2018, the same teams launched what was then known as the Philadelphia-Newark Regional Strike Force, before reducing its operations to Newark-only in more recent years. Nationally, since its inception in 2007, the Health Care Fraud Strike Force program has been responsible for prosecuting more than 6,200 defendants who collectively billed federal health care programs and private insurers more than $45 billion.
(more…)
Lisa H. Miller
Washington, D.C.
lisa.miller@sidley.com
Jaime L.M. Jones
Chicago
jaime.jones@sidley.com
Matt Bergs
Chicago
mbergs@sidley.com
DOJ Loosens the Whistleblower Program’s Bar on “Other Program” Claimants in Latest Revision
On July 30, 2026, the U.S. Department of Justice (DOJ) revised its Corporate Whistleblower Awards Pilot Program, expanding the pool of individuals who may qualify for an award. Most notably, DOJ eliminated the prior rule that automatically disqualified whistleblowers who could have been eligible for an award under another U.S. government whistleblower program, such as those administered by the SEC or CFTC. Instead, a whistleblower is now disqualified only if he or she actually receives an award from another program for reporting the same or substantially the same misconduct, while DOJ retains discretion to reduce or deny duplicative awards.
The revised guidance also includes several administrative updates, including confirmation that the program is now administered by the Criminal Division’s Money Laundering, Narcotics, and Forfeiture Section (formerly the Money Laundering and Asset Recovery Section) and that submissions will be made through a dedicated online intake portal. The covered subject-matter areas remain unchanged from the May 2025 expansion and continue to include, among other areas, financial institution crimes, bribery, healthcare fraud, trade and customs fraud, procurement fraud, immigration offenses, and sanctions-related misconduct.
For companies, the revisions further strengthen incentives for whistleblowers to report directly to DOJ, including in matters that may also be eligible for other agency whistleblower programs. At the same time, DOJ’s Corporate Enforcement and Voluntary Self-Disclosure Policy continues to provide a pathway to a declination for companies that promptly self-disclose, cooperate, and remediate misconduct, reinforcing the importance of effective internal reporting mechanisms and careful consideration of self-disclosure decisions in the face of potential whistleblower reports. Click here to read the full post.
Kenneth A. Polite Jr.
Washington, D.C., New York
kpolite@sidley.com
Lisa H. Miller
Washington, D.C.
lisa.miller@sidley.com
Michael D. Mann
New York
mdmann@sidley.com
Craig Francis Dukin
Washington, D.C.
cdukin@sidley.com
Kenneth G. Coffin
Dallas
kenneth.coffin@sidley.com
Mallory W. Edel
New York
medel@sidley.com
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.
Jaime L.M. Jones
Chicago
jaime.jones@sidley.com
Lisa H. Miller
Washington, D.C.
lisa.miller@sidley.com
Matt Bergs
Chicago
mbergs@sidley.com
Laboratory, Owners, and Investors Settle COVID-19 Testing Fraud Allegations for $24 Million
On July 23, 2026, the Department of Justice announced that clinical lab Magnolia Diagnostics and its owners agreed to pay $19.2 million to resolve allegations that they violated the False Claims Act by billing Medicare for medically unnecessary respiratory pathogen panel (“RPP”) testing performed in connection with COVID-19 testing at senior living communities. Notably, Magnolia’s investors separately agreed to pay an additional $4.8 million to resolve alleged common law claims for unjust enrichment and payment by mistake and claims under the Federal Debt Collection Procedures Act arising from distributions they received from the laboratory. Assistant Attorney General Brett Shumate emphasized that the Department will seek to hold accountable not only entities that submit false claims, but also individuals and investors who allegedly benefit from fraudulent conduct, which is consistent with previous statements of DOJ’s enforcement priorities and resolutions, as we covered here and here.
(more…)
Jaime L.M. Jones
Chicago
jaime.jones@sidley.com
Michael D. Mann
New York
mdmann@sidley.com
Lauren E. McBride
Chicago
lmcbride@sidley.com
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.
Kristin Graham Koehler
Washington, D.C.
kkoehler@sidley.com
Ted Murphy
Washington, D.C.
ted.murphy@sidley.com
Aaron M. Applebaum
Washington, D.C.
aapplebaum@sidley.com
Anna Carney
Washington, D.C.
anna.carney@sidley.com
Craig Francis Dukin
Washington, D.C.
cdukin@sidley.com
Sidley’s Antitrust and Competition Bulletin: U.S. and EU Authorities Signal Evolving Enforcement Priorities
Antitrust enforcement continues to evolve on both sides of the Atlantic, with regulators sharpening their focus on consumer pricing, merger oversight, and national security review. The July 2026 edition of Sidley’s Antitrust and Competition Bulletin highlights several recent developments that signal where enforcement priorities may be headed.
This issue covers the DOJ and FTC’s call for state Attorneys General to investigate potential anticompetitive practices affecting gasoline prices, the Supreme Court’s decision in Trump v. Slaughter expanding presidential authority over FTC commissioners, the FTC’s $12 million HSR settlement, new guidance from the European Competition Network on merger call-in powers, and the EU’s adoption of updated foreign investment screening rules.
Click here to read the full bulletin for Sidley’s perspective on what these developments mean for businesses navigating antitrust compliance, M&A transactions, and an increasingly active global enforcement landscape.
White Collar Watch
Delaware Supreme Court Rejects Jarkesy-Based Jury Trial Challenge to State Administrative Enforcement Proceeding
On July 16, the Delaware Supreme Court held that defendants facing securities fraud and registration claims in administrative proceedings brought by the Delaware Investor Protection Unit are not entitled to a jury trial under the Delaware Constitution, distinguishing the U.S. Supreme Court’s decision in SEC v. Jarkesy. Applying its recently adopted Blue Beach Bungalows framework, the court concluded that the state statutory claims are not sufficiently analogous to common-law actions historically tried before a jury, despite the availability of monetary penalties.
The decision underscores that jury-trial challenges to state administrative enforcement actions will turn on the text and history of each state’s constitution and statutory scheme, rather than Jarkesy alone. With similar challenges pending in other jurisdictions, including Arizona, the ruling provides important guidance for regulators and litigants assessing the continued viability of administrative enforcement proceedings seeking civil penalties. Click here to read the full blog post.
Ike Adams
Washington, D.C.
iadams@sidley.com
Kathryn L. Alessi
Boston
kalessi@sidley.com
W. Hardy Callcott
San Francisco
wcallcott@sidley.com
Kevin J. Campion
Washington, D.C.
kcampion@sidley.com
Stephen L. Cohen
Washington, D.C., Boston, ...
scohen@sidley.com
Ranah Esmaili
Washington, D.C., New York
resmaili@sidley.com
Kenyon Hall
Boston
kenyon.hall@sidley.com
Elizabeth A. Marino
Boston
emarino@sidley.com
Ian McGinley
New York
ian.mcginley@sidley.com
Lara Mehraban
New York
lmehraban@sidley.com
Christopher R. Mills
Washington, D.C.
cmills@sidley.com
David S. Petron
Washington, D.C.
dpetron@sidley.com
John I. Sakhleh
Washington, D.C.
jsakhleh@sidley.com
Charles A. Sommers
Washington, D.C.
csommers@sidley.com
Simona K. Suh
New York
simona.suh@sidley.com
Corin R. Swift
New York, Boston
corin.swift@sidley.com
Lara C. Thyagarajan
New York, Boston
lthyagarajan@sidley.com
Paul M. Tyrrell
Boston
ptyrrell@sidley.com
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