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Articles by Christopher Kavanaugh
DOJ Revises Justice Manual Sections on False Claims Act Enforcement
On Friday, September 18, 2026, the U.S. Department of Justice (DOJ) announced revisions to two Justice Manual sections governing False Claims Act (FCA) enforcement. The revisions narrow DOJ’s enforcement approach in two respects.
Unpacking Enforcement Challenges Of DOJ's Bulk Data Rule
By Christopher Kavanaugh, David Last and Katie McGuire ( July 17, 2025, 5:08 PM EDT) -- On July 8, the U.S. Department of Justice began full enforcement of its data security program and the recently issued bulk data rule after the expiration of its 90-day limited enforcement policy, ushering in full compliance requirements for U.S. companies and individuals.[1]... Law360 is on it, so you are, too.
Enforcement Countdown: Is DOJ Ready for the Bulk Data Rule “Grace Period” to End?
As of July 8, the U.S. Department of Justice (“DOJ”) is scheduled to begin full enforcement of its Data Security Program (“DSP”) and the recently issued Bulk Data Rule after its 90-day limited enforcement policy expires, ushering in “full compliance” requirements for U.S. companies and individuals.[1] Although it remains to be seen whether DOJ’s National Security Division (“NSD”) will have the necessary infrastructure and personnel in place to launch comprehensive investigations to enforce...
DOJ National Security Division Issues First Declination Under Merger-Related Safe Harbor Provisions
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 of sanctions violations committed by an acquired company.[1] This marks the first application of the safe harbor provisions for voluntary self-disclosure in connection with mergers and acquisitions—a policy put in...
David A. Last - Concurrences
David A. Last is partner with Cleary Gottlieb, based in Washington D.C. office. His practice focuses on government and internal investigations, including defending companies and individuals in a wide range of high-stakes domestic and international enforcement actions and trials with a particular focus on Foreign Corrupt Practices Act (FCPA) matters. David brings extensive experience in leading investigations related to white collar criminal offenses, with a particular focus on FCPA matters.
Christopher Kavanaugh – Concurrences
Cleary Gottlieb Steen & Hamilton (Washington) Partner Chris Kavanaugh is a partner at Cleary Gottlieb Steen & Hamilton LLP, based in the firm’s Washington D.C. office. He is practice focuses on enforcement and litigation, including government and internal investigations, white-collar criminal defense, high-stakes trials, and crisis management.
Breon S. Peace - Concurrences
Breon Peace is a partner at Cleary Gottlieb Steen & Hamilton LLP, based in the firm’s New York office. He is practice focuses on a range of high-stakes complex litigation, regulatory and enforcement matters, government and internal investigations, and white-collar defense.
On April 30, 2025, the Department of Justice’s (“DOJ”) National Security Division (“NSD”), alongside the U.S. Attorney’s Office for the Northern District of California, announced a declination to prosecute Universities Space Research Association (“USRA”) for criminal export control violations committed by a former employee.[1] This marks only the second declination issued by NSD under its Enforcement Policy for Business Organizations (the “Policy”), following voluntary self-disclosure.
DOJ Issues Additional Guidance as Data Security Program Enters into Effect; Limits Enforcement for First 90 Days
On April 11, 2025, the U.S. Department of Justice, National Security Division (“DOJ”) issued a compliance guide (“Compliance Guide”), a set of frequently asked questions (“FAQs”), and a 90-day limited enforcement policy (“Enforcement Policy”) relating to implementation of the Data Security Program, codified at 28 C.F.R. Part 202 (“DSP”).
U.S. Government Signals Intent to Increase Enforcement of U.S. Export Controls
Earlier this month, the U.S. Department of Commerce (Commerce), Bureau of Industry and Security (BIS) held its annual Update Conference on Export Controls and Policy (the Conference). During the Conference, key government officials signaled an intent to ramp up enforcement of the Export Administration Regulations (EAR) going forward.
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