On March 10, 2026, the Department of Justice announced its first ever Department-wide corporate enforcement policy for all criminal cases.  Under the new policy, companies that self-report misconduct could be eligible for a declination and avoid fines or monitors.

The …

In 2025, U.S. Department of Justice (“DOJ” or the “Department”) leaders announced significant recalibrations of the Department’s corporate enforcement priorities. For example, in a May 12, 2025 memorandum from then-Acting Assistant Attorney General of DOJ’s Criminal Division, Matthew R. Galeotti, …

On November 12, 2025, the U.S. Department of Justice (“DOJ”) announced the launch of a cross-agency strike force targeting the type of cryptocurrency-related scam known as pig butchering.[1] For companies involved in digital asset transactions, this enforcement initiative carries …

On November 25, 2025, the DOJ announced that it agreed to settle claims that RealPage, Inc. (RealPage) violated Section 1 of the Sherman Act by unlawfully sharing competing users’ competitively sensitive information for use in competitors’ pricing and by entering …

On November 10, 2025, Comunicaciones Celulares S.A. (“Comcel” d/b/a “TIGO Guatemala (“TIGO”)”), a subsidiary of Millicom International Cellular (“Millicom”), a Luxembourg company, entered into a deferred prosecution agreement (“DPA”) with the Department of Justice (“DOJ”) to resolve a criminal investigation …

Over the past three years, courts across the country have evaluated the use of pricing algorithms under the antitrust laws. In 2022, private plaintiffs filed the first of many civil cases involving algorithmic pricing against software provider RealPage and its …

In recent years, state Attorneys General (AGs) have taken a more active approach in antitrust enforcement matters related to mergers and acquisitions.  For example, earlier this year, laws in Washington and Colorado requiring parties to submit pre-merger notification filings went …

On October 6, 2025, Governor Gavin Newsom signed into law California Senate Bill No. 763 (SB 763), effective January 1, 2026, which increases the maximum corporate criminal antitrust penalties in California to $6 million and provides for new civil penalties …

On October 14, 2025, the Department of Justice (DOJ), the Department of Treasury’s Office of Foreign Assets Control (OFAC), and Treasury’s Financial Crimes Enforcement Network (FinCEN) announced significant enforcement actions against Southeast-Asian scam networks targeting Americans through “pig butchering” cryptocurrency …

As predicted, antitrust merger enforcement under the second Trump Administration exhibits a return to a more restrained approach at both the Federal Trade Commission and the Antitrust Division of the Department of Justice.  Most refreshingly, the agencies appear committed …

On July 2, 2025, the Department of Health and Human Services (HHS) and the Department of Justice (DOJ) announced the reinvigoration of their False Claims Act (FCA) enforcement efforts through the formation of a joint FCA Working Group. The announcement …

On June 16, 2025, the Department of Justice’s National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas announced a landmark declination to prosecute private equity firm White Deer Management LLC following its voluntary self-disclosure …

On June 5, 2025, the Head of the Criminal Division of the Department of Justice (“DOJ”), Matthew R. Galeotti, issued a memorandum providing guidance to Criminal Division prosecutors on corporate resolutions involving parallel criminal, civil, regulatory, and administrative proceedings by …

The Federal Trade Commission and the DOJ’s Antitrust Division recently announced two settlement agreements, signaling that this Administration is willing to resolve merger competition concerns — in appropriate cases — through negotiated divestiture remedies.  These actions herald a return to …