New Division Continues Time-Tested Model: DOJ’s National Fraud Enforcement Division Launches West Coast Health Care Fraud Strike Force

In another signal that health care fraud enforcement remains a top priority for DOJ, on April 30, 2026, the newly created National Fraud Enforcement Division (the “Fraud Division”) announced the launch of the West Coast Health Care Fraud Strike Force, a multi-district initiative targeting health care fraud across the District of Arizona, the District of Nevada, and the Northern District of California. This expansion is consistent with the time-tested model of Main Justice-based health care matters that has existed since 2007. Like its predecessor strike forces, the West Coast Strike Force will use dedicated agent and prosecutorial resources in the region to combat schemes identified based on data analytics and traditional law enforcement techniques. This announcement is independently notable because it makes clear that while the Health Care Fraud Unit—rebranded as the Health Care Section of the new Fraud Division—is no longer part of the Criminal Division, it will continue with the same career leadership and approach to enforcement: use of data to expand prosecutorial pipelines, solicitation of whistleblowers, and aggressive pursuit of corporate and individual prosecutions.

Clear and Present Danger: DOJ Trade Fraud and Anti-Corruption Priorities Signal Lasting Compliance Risk

This article, “Clear and Present Danger: How U.S. Department of Justice Trade-Fraud and Anti-Corruption Priorities Show Trade and Customs Risks Are Here to Stay,” published in The Global Trade Law Journal, examines the DOJ’s increased focus on trade fraud, tariff evasion and Foreign Corrupt Practices Act risks. The authors highlight key enforcement trends, including expanded whistleblower incentives and renewed use of the Trade Fraud Task Force, and explain how these developments are driving more aggressive investigations. The article also outlines practical steps companies can take to strengthen trade compliance, enhance oversight of third-party intermediaries and reduce enforcement risk.

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New Guidance on U.S. Procurement Raises Risk to Federal Contractors From Potentially Discriminatory Practices

 The Trump Administration is advancing a coordinated effort to tie federal funding and contracting eligibility more closely to its interpretation of antidiscrimination law. Recent Federal Acquisition Regulation (FAR) guidance directs agencies to incorporate a new contract clause prohibiting practices the Administration deems discriminatory, while proposed revisions to System for Award Management (SAM) certifications would require recipients of federal grants and other financial assistance to affirm compliance with similar standards. These developments build on earlier Department of Justice guidance outlining the types of conduct the Administration views as unlawful and are reinforced by a recent False Claims Act (FCA) settlement signaling a willingness to pursue enforcement in this area. Together, the FAR changes and proposed SAM revisions point to a more integrated enforcement framework—one that expands certification and disclosure obligations, links compliance more directly to FCA materiality, and increases oversight and reporting expectations. For federal contractors and grant recipients, the result is a heightened risk environment requiring careful reassessment of policies, internal controls, and subcontractor compliance in anticipation of greater scrutiny from both contracting agencies and enforcement authorities.

DOJ and DEA Loosen Medical Marijuana Restrictions and Move Toward Broader Rescheduling

On April 22, 2026, DOJ and DEA took two coordinated steps that could reshape—though not resolve—the federal treatment of marijuana. First, they issued a final order placing certain FDA-approved and state-licensed medical marijuana products in Schedule III of the Controlled Substances Act. At the same time, DEA announced an expedited hearing on a separate proposal to reclassify marijuana more broadly from Schedule I to Schedule III, with proceedings set to begin in late June. Together, these actions signal movement toward a less restrictive federal framework, but their immediate impact is narrower than it may appear: the final order applies only to a limited subset of medical marijuana products and leaves most cannabis activity subject to existing federal controls. For industry participants, the developments introduce a more compliance-driven, state license-dependent pathway today, while setting the stage for potentially more significant changes in the months ahead.

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April Antitrust and Competition Bulletin: Top-of-Mind Global Antitrust Issues

Sidley’s global Antitrust and Competition team recently shared its perspectives on key antitrust issues currently top of mind—and why they matter for businesses. The April Antitrust and Competition Bulletin highlights continued scrutiny by the U.S. Department of Justice and Federal Trade Commission of labor markets, including noncompete agreements and talent-focused transactions, as well as evolving enforcement approaches to information exchanges, as reflected in the DOJ’s recent statement in In re Turkey Antitrust Litigation. It also examines the growing willingness of state Attorneys General to act independently of federal enforcers, signaling an increasingly complex enforcement landscape. In addition, the team addresses notable international developments, including leadership changes at the European Commission’s Directorate-General for Competition and new guidance on the interplay between the Digital Markets Act and the General Data Protection Regulation. The Bulletin further explores how these developments may affect businesses.

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Seventh Circuit Orders Release of Sidley Client

On April 14, 2026, a Seventh Circuit panel took the rare step of ordering the immediate release of Sidley client Anne Pramaggiore from federal custody pending a new trial. Pramaggiore, the former CEO of Commonwealth Edison, was convicted in May 2023 of charges including violations of the federal programs bribery statute (18 U.S.C. § 666), violations of books-and-records provisions of the Foreign Corrupt Practices Act (FCPA), and conspiracy. Following the Supreme Court’s decision in Snyder v. United States, 603 U.S. 1 (2024), the District Court vacated the bribery convictions but left the remaining convictions intact. On appeal, the Seventh Circuit panel indicated that because two of the alleged objects of the conspiracy were invalid following Snyder, the jury returned a general verdict form not specifying what object of the conspiracy it found the defendants agreed to commit, and the jury had received a co-conspirator liability instruction (commonly known as a Pinkerton instruction) over a defense objection, it would be impossible to tell whether the remaining convictions rested on valid or invalid grounds. A full written opinion is expected to follow.

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Clayton Addresses the Uncertainty Surrounding SDNY’s Self-Disclosure Program

On April 14, 2026, at a conference hosted by New York University School of Law’s Program on Corporate Compliance and Enforcement, Jay Clayton, the U.S. Attorney for the Southern District of New York (SDNY), publicly addressed whether the Department of Justice (DOJ)’s recently announced Department-wide Corporate Enforcement and Voluntary Self-Disclosure Program (CEP) supersedes SDNY’s own Corporate Enforcement and Voluntary Self-Disclosure and Cooperation Program (the SDNY Program). Clayton stated that the two policies are not in tension and that his Office continues to invite companies to self-report misconduct under the SDNY Program.

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Evolving AML/CFT Expectations and Enforcement Priorities as FinCEN Releases FY 2025 Year in Review

On April 16, 2026, the Financial Crimes Enforcement Network (“FinCEN”) released its Year in Review for Fiscal Year 2025 (the “FY 2025 Report”). The report provides a concise overview of recent regulatory and enforcement developments in the financial crimes space and offers insight into FinCEN’s evolving priorities.

FinCEN highlights several key accomplishments over the past year, including reporting $10 billion in savings attributed to deregulatory efforts, enhancing the management and sharing of Bank Secrecy Act (“BSA”) data with law enforcement, and expanding engagement with private-sector stakeholders on anti-money laundering and countering the financing of terrorism (“AML/CFT”) issues.

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Meet the Team

<a target=‘_blank’ href="https://www.sidley.com/en/people/a/axel-douglas-a">Douglas A. Axel</a>

Douglas A. Axel

Los Angeles
<a target=‘_blank’ href="https://www.sidley.com/en/people/l/loughnane-joan-m">Joan M. Loughnane</a>

Joan M. Loughnane

New York
<a target=‘_blank’ href="https://www.sidley.com/en/people/p/polite-jr-kenneth-a">Kenneth A. Polite Jr.</a>

Kenneth A. Polite Jr.

Washington, D.C., New York
<a target=‘_blank’ href="https://www.sidley.com/en/people/t/tham-yuet-ming">Yuet Ming Tham</a>

Yuet Ming Tham

Singapore, Hong Kong
<a target=‘_blank’ href="https://www.sidley.com/en/people/a/anderson-dave">Dave Anderson</a>

Dave Anderson

San Francisco
<a target=‘_blank’ href="https://www.sidley.com/en/people/a/armbrust-sheila-a-g">Sheila A.G. Armbrust</a>

Sheila A.G. Armbrust

San Francisco
<a target=‘_blank’ href="https://www.sidley.com/en/people/c/cooper-ellyce-r">Ellyce R. Cooper</a>

Ellyce R. Cooper

Century City
<a target=‘_blank’ href="https://www.sidley.com/en/people/c/craig-daniel-c">Daniel C. Craig</a>

Daniel C. Craig

Chicago
<a target=‘_blank’ href="">Alexandria Daugherty</a>

Alexandria Daugherty

Los Angeles
<a target=‘_blank’ href="https://www.sidley.com/en/people/d/dukin-craig-francis">Craig Francis Dukin</a>

Craig Francis Dukin

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/g/george-sara">Sara George</a>

Sara George

London
<a target=‘_blank’ href="https://www.sidley.com/en/people/h/ho-shu-min">Shu Min Ho</a>

Shu Min Ho

Singapore
<a target=‘_blank’ href="https://www.sidley.com/en/people/i/igra-naomi-a">Naomi A. Igra</a>

Naomi A. Igra

San Francisco
<a target=‘_blank’ href="https://www.sidley.com/en/people/k/koehler-kristin-graham">Kristin Graham Koehler</a>

Kristin Graham Koehler

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/l/lassar-scott-r">Scott R. Lassar</a>

Scott R. Lassar

Chicago
<a target=‘_blank’ href="https://www.sidley.com/en/people/l/levy-michael-a">Michael A. Levy</a>

Michael A. Levy

New York

<a target=‘_blank’ href="https://www.sidley.com/en/people/m/malhotra-geeta">Geeta Malhotra</a>

Geeta Malhotra

Chicago
<a target=‘_blank’ href="https://www.sidley.com/en/people/m/mann-michael-d">Michael D. Mann</a>

Michael D. Mann

New York
<a target=‘_blank’ href="https://www.sidley.com/en/people/m/mcginley-ian">Ian McGinley</a>

Ian McGinley

New York
<a target=‘_blank’ href="https://www.sidley.com/en/people/m/miller-lisa-h">Lisa H. Miller</a>

Lisa H. Miller

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/m/mirabella-julia-g">Julia G. Mirabella</a>

Julia G. Mirabella

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/o/ono-takayuki">Takayuki Ono</a>

Takayuki Ono

Chicago, Tokyo
<a target=‘_blank’ href="https://www.sidley.com/en/people/p/poletto-alexa">Alexa Poletto</a>

Alexa Poletto

New York
<a target=‘_blank’ href="https://www.sidley.com/en/people/p/popp-karen-a">Karen A. Popp</a>

Karen A. Popp

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/p/pruitt-jacqueline">Jacqueline Pruitt</a>

Jacqueline Pruitt

Chicago
<a target=‘_blank’ href="https://www.sidley.com/en/people/r/rachal-doreen-m">Doreen M. Rachal</a>

Doreen M. Rachal

New York, Boston

<a target=‘_blank’ href="https://www.sidley.com/en/people/r/rubino-kevin-r">Kevin Rubino</a>

Kevin Rubino

San Francisco
<a target=‘_blank’ href="https://www.sidley.com/en/people/s/shubert-leslie-a">Leslie A. Shubert</a>

Leslie A. Shubert

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/s/silva-david-a">David A. Silva</a>

David A. Silva

Singapore
<a target=‘_blank’ href="https://www.sidley.com/en/people/t/tagliaferri-michele">Michele Tagliaferri</a>

Michele Tagliaferri

Brussels
<a target=‘_blank’ href="https://www.sidley.com/en/people/v/volpe-frank-r">Frank R. Volpe</a>

Frank R. Volpe

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/w/west-marisa-s">Marisa S. West</a>

Marisa S. West

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/x/xenakis-angela-m">Angela M. Xenakis</a>

Angela M. Xenakis

Washington, D.C.
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