DOJ’s National Fraud Enforcement Division Outlines Corporate Enforcement Priorities and Charging Factors

On October 1, 2026, Assistant Attorney General Colin M. McDonald issued Directive 26-12, “Corporate Enforcement in the Fight Against Fraud,” (“Directive 26-12”) to all personnel of the Department of Justice’s (“DOJ”) newly created National Fraud Enforcement Division (the “Fraud Division”). Significantly, the Fraud Division promises an “aggressive, all-tools approach” to corporate fraud, run through its newly centralized Corporate Enforcement Section and guided by a published list of priorities and aggravating factors. A week later, McDonald issued “A Comprehensive Approach in the Fight Against Fraud” (Oct. 7, 2026) (“Directive 26-13”), placing these corporate enforcement priorities within a broader strategy emphasizing additional charges, early asset recovery and disruption, proactive cooperators, and aggressive sentencing advocacy.

The False Claims Act Takes Center Stage in the Trump Administration’s Anti-Fraud Strategy

By Lauren Briggerman and Lauryn Durham on August 31, 2026 Posted in General

Over the past year, the Trump Administration has prioritized the False Claims Act (“FCA”) as a primary weapon to combat federal program fraud. Most recently, in May, Assistant Attorney General Brett A. Shumate of the US Department of Justice’s (“DOJ”) Civil Division announced new guidelines to accelerate the investigation and prosecution of qui tam whistleblower actions that allege fraud on federally funded, state-administered benefits programs. Specifically, AAG Shumate’s memorandum (the “Shumate Memo”) provides for:

Expedited government investigation of qui tam complaints through mandatory DOJ review timeframes of no more than 120 days;
An increased role for relators in developing evidence in FCA investigations; and
Improved coordination among government agencies in which benefits-fraud allegations may be simultaneously reviewed for civil, criminal, and administrative enforcement.

Deeming the FCA “one of the government’s most powerful weapons for fighting fraud and ensuring that government funds are spent properly,” the Shumate Memo reflects the DOJ’s latest effort to aggressively combat fraud involving federal programs.

EU CS3D and CSRD: U.S. Government requests changes for U.S. companies

By Thomas Delille, Marion Seranne, Ayako Russell and Guillermo Giralda Fustes on August 31, 2026 Posted in General

In a document posted by the U.S. Mission to the European Union and disseminated on August 14, 2026 via social media by Ambassador Andrew Puzder, the U.S. Government[1] voiced concerns on the “burden” that recent EU ESG legislation creates for U.S. companies, namely the EU’s Corporate Sustainability Due Diligence Directive (CS3D, available here) and Corporate Sustainability Reporting Directive (CSRD, available here).

The U.S. Government’s comments have been published here, coinciding with the European Commission’s (EC) preparation of guidelines for the CS3D’s implementation. They were also shared in advance of the first anniversary of the 21 August 2025 U.S.-EU Joint Statement (the Turnberry Agreement, available here), in which the EU committed to undertake efforts so that the CS3D and the CSRD do not pose undue restrictions on bilateral trade.

DOJ Signals shift to more aggressive trade enforcement as new Trade Fraud Task Force seizes over US$1 billion

By Squire Patton Boggs on August 18, 2026 Posted in General

The Department of Justice (DOJ) and Department of Homeland Security (DHS) recently announced that their joint Trade Fraud Task Force (TFTF) has generated more than US$1 billion in recoveries, penalties and forfeitures since its creation in August 2025. Federal authorities also unveiled a new DOJ litigation section focused on trade-related violations and issued a resource guide describing the government’s enforcement framework in this area. Taken together, these actions reflect an increasingly coordinated federal effort to address customs fraud and other import-related violations through not only administrative, but also criminal and civil enforcement, underscoring the importance of effective trade compliance programs for businesses engaged in international commerce.

SPB’s D. Michael Kaye, Tom Firestone, Chris Duncan and Mirrah Papovsky recently published an update examining these developments. Read the full insight here.

From the World Cup to the Courtroom: Wayne Barnes on Sport and the Law

By Squire Patton Boggs on August 12, 2026 Posted in Podcast

On the latest episode of Bad News, Good Lawyers, Tom Firestone, head of our Government Investigations & White Collar Practice, welcomes Wayne Barnes, a Squire Patton Boggs partner, one of the most accomplished rugby referees in the history of the sport and author of Throwing the Book: The Strife and Crimes of a Rugby Referee.

Wayne discusses his journey from community rugby in rural England to the international stage as referee for the Rugby World Cup 2023 final. Along the way, he built a distinguished legal career, giving him a unique perspective on the parallels between sport and legal practice.

Tom and Wayne examine the common challenges faced by referees and lawyers, what lawyers can learn from sport, what sport can learn from the law and how both fields confront questions of fairness, trust and integrity. They also discuss the impact of technology on modern sport and the ongoing challenge of combating corruption and maintaining public confidence in sport.

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Giancarlo Pellegrini on Do’s and Don’ts of Congressional Investigations

By Squire Patton Boggs on August 3, 2026 Posted in Bad News, Good Lawyers, Podcast

In this episode of Bad News, Good Lawyers, Tom Firestone, head of our Government Investigations & White Collar Practice sits down with Giancarlo Pellegrini, former senior counsel to the US House Committee on Oversight and Government Reform, to discuss his experience leading some of the nation’s most high-profile congressional investigations, including Congress’ investigation of Jeffrey Epstein’s crimes.

Drawing on his time on Capitol Hill, Giancarlo provides an insider’s perspective on questioning some of the most prominent witnesses to appear before congressional committees, including former President Bill Clinton and former Secretary of State Hillary Clinton.

The conversation examines the unique dynamics of congressional investigations and the challenges they present for both witnesses and counsel. Giancarlo also discusses why congressional investigations differ from traditional legal proceedings, why companies may face heightened scrutiny after the US midterm elections and what companies should be doing now to prepare for a potential increase in oversight activity.

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OFAC and OFSI Publish Joint Guidance on US and UK Sanctions

By Richard Gibbon, Hannah Laming, Adam Klauder, Katy Fisher and Elgun Ganizade on July 31, 2026 Posted in General, OFAC, OFSI

On June 23, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) and His Majesty’s Treasury’s Office of Financial Sanctions Implementation (OFSI) published joint guidance (Guidance) setting out important similarities and differences between the two sanctions regimes. The Guidance is published under OFAC-OFSI Enhanced Partnership, which is now into its fifth year, and aims to help private sector actors understand their multijurisdictional sanctions compliance obligations.

Navigating Chaos, Corruption and Murder in Post-Soviet Russia

By Squire Patton Boggs on July 22, 2026 Posted in General, Podcast

On the latest episode of Bad News, Good Lawyers, host Tom Firestone welcomes Jamison Firestone (no relation), founder of the first independent foreign law firm in post-Soviet Russia.

Drawing on stories from his new book, Rule of Lies: My Wild Ride Through Chaos, Corruption, and Murder in Putin’s Russia, Jamison describes his experiences in early post-Soviet Russia, including the murder of his law partner who died trying to defend Russian democracy, how his father (a convicted felon) tried to have his law partner seriously injured, his work with Sergei Magnitsky and his role in getting the Magnitsky Act passed by Congress. Tom and Jamison also discuss Jamison’s ongoing efforts to support Ukraine through the use of frozen Russian state assets and the legal and policy questions surrounding those efforts.

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Michael Missal on Leading Oversight at the Department of Veterans Affairs

By Squire Patton Boggs on July 21, 2026 Posted in General, Inspector General, Podcast

In the latest episode of The Inspector General, host Clark Ervin of our Government Investigations & White Collar Practice sits down with Michael Missal, former Inspector General of the U.S. Department of Veterans Affairs (VA), to discuss the challenges and opportunities of overseeing one of the federal government’s largest and most complex agencies.

Although often overlooked in discussions of the federal bureaucracy, the VA manages a vast enterprise, with a budget exceeding $350 billion, a workforce of roughly 500,000 employees and the nation’s largest integrated healthcare system.

During his nine years as Inspector General, Missal led a multidisciplinary team of auditors, investigators and healthcare professionals and issued approximately 2,500 reports, made more than 10,000 recommendations and generated an estimated $4.5 billion in monetary impact. In this episode, Missal reflects on some of the audits and investigations that drew national attention, explaining how oversight efforts helped strengthen agency operations and improve services for veterans across the country.

The conversation also explores the importance of Inspector General independence, the tools available to oversight offices and the balance required to maintain productive relationships with agency leadership and Congress.

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Flipping the Real-Life Sopranos: How the FBI Dismantled a Notorious Crime Family

By Squire Patton Boggs on July 8, 2026 Posted in General, Podcast

In this episode of Bad News, Good Lawyers, host Tom Firestone, head of our Government Investigations & White Collar Practice, speaks with Séamus McElearney, a retired FBI Special Agent and author of Flipping Capo: How the FBI Dismantled the Real Sopranos, about the investigation that helped dismantle the DeCavalcante organized crime family (the model for the Sopranos).

McElearney explains how he and his colleagues secured the cooperation of Anthony Capo, a member of the DeCavalcante organized crime family, paving the way for additional members and associates to come forward and helping investigators solve 11 murders and secure convictions against 71 defendants.

The conversation explores the challenges of developing cooperating witnesses within organized crime organizations and the broader impact the investigation had on the FBI’s efforts against La Cosa Nostra. McElearney also discusses the connection between the DeCavalcante family and HBO’s The Sopranos, sharing how real-life figures reacted to the series and which storylines were inspired by actual events.

This episode offers a rare insider’s perspective on organized crime investigations, witness cooperation and the real-world history behind one of television’s most iconic crime dramas.

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