Derek Hahn
Irvine
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Articles by Derek Hahn
Digging Into Dems' Letter On Subpoena Secrecy Demands
By Derek Hahn, Ross Garrett and Ahnna Chu ( October 26, 2026, 2:04 PM EDT) -- Federal law enforcement agencies routinely use boilerplate language in their subpoenas — or the cover letters accompanying them — directing companies not to notify the subpoena's ultimate targets, such as the company's customers or others. And oftentimes, these documents imply that disclosure could have legal consequences.... Law360 is on it, so you are, too.
Client Alert: DOJ Fraud Division Issues Corporate Enforcement Directive
Derek Hahn is a partner in Crowell & Moring’s White Collar & Regulatory Enforcement Group and a member of the firm’s Investigation Practice. Derek’s practice focuses on white collar defense, internal investigations, complex litigation, and compliance counseling. He represents clients in an array of government investigations and enforcement actions alleging financial fraud, public corruption, conflicts of interest, counterfeiting, procurement integrity, and health care fraud.
Congressional Letter Puts Spotlight On Unenforceable Secrecy Demands In Federal Subpoenas
Key takeaway #1 A recent congressional oversight letter is drawing new attention to a long-standing practice by federal agencies of embedding nondisclosure language in subpoenas for customer data, which the lawmakers argue carries no legal force on its own. Key takeaway #2 Companies that have been treating these secrecy requests as binding should take note that they may not be enforceable.
DOJ And DHS Announce Cross-Agency Trade Fraud Task Force
Key takeaway #1 Customs and Trade Fraud is a DOJ Priority The new Trade Fraud Task Force underscores DOJ's recently enhanced focus on customs enforcement. Earlier this year, DOJ identified trade fraud as top enforcement priority, and announced a restructuring of its Fraud section as part of its efforts to focus more enforcement resources in this area.
FCPA Enforcement Continues To Evolve With Newly Unsealed Indictment
Key takeaway #1 DOJ is actively pursuing FCPA investigations and enforcement actions, including "run of the mill" bribery cases, even under its new guidelines Key takeaway #2 While DOJ referenced cartel ties in court filings (one of its new focus areas for FCPA enforcement), it is unclear whether that was a driver for bringing this indictment; other factors such as the substantial bribes and contracts involved, or the impact on fair market competition for U.S. companies, are also potentially...
FCPA Under Fire: What Companies Need to Consider After Trump’s Executive Order
Executive Order Pauses Enforcement: President Trump’s 2025 order halts new FCPA investigations for 180 days, directing a DOJ review to align enforcement with the President’s agenda regarding U.S. economic and national security interests. The Order also requires new guidance on FCPA enforcement be provided and allows DOJ to extend the pause for an additional 180 days.
US Tariff Enforcement Risk Continues To Rise As DOJ Assigns Unit To Criminally Prosecute Violators
Briefing. The Trump administration continues to raise the stakes for importers and other actors in the international trade space. Bloomberg Law reports that the Department of Justice has tasked its MIMF (Market Integrity and Major Frauds) Unit with investigating fraud schemes by companies dodging U.S. tariffs.
Ninth Circuit Decision Underscores Increasing False Claims Act Risks to U.S. Importers
On June 23, 2025, the Ninth Circuit issued a long-awaited decision in Island Industries Inc. v. Sigma Corp. affirming a $26M False Claims Act (“FCA”) judgment against the defendant importer. Sigma had appealed the judgment after a jury found the company violated the FCA by failing to pay customs duties owed to U.S. Customs and Border Protection (“CBP”).
Ninth Circuit Decision Underscores Increasing False Claims Act Risks To U.S. Importers
On June 23, 2025, the Ninth Circuit issued a long-awaited decision in Island Industries Inc. v. Sigma Corp. affirming a $26M False Claims Act ("FCA") judgment against the defendant importer. Sigma had appealed the judgment after a jury found the company violated the FCA by failing to pay customs duties owed to U.S. Customs and Border Protection ("CBP").
The FCPA Pause Is Over: Trump DOJ Issues Long-Awaited FCPA Investigations And Enforcement Guidelines
On June 9, 2025, U.S. Department of Justice ("DOJ") Deputy Attorney General Todd Blanche issued new Foreign Corrupt Practices Act ("FCPA") enforcement guidelines ("the Guidelines"). DOJ issued the Guidelines in response to the Trump Administration's February 2025 Executive Order ("EO"), which paused FCPA enforcement pending the issuance of new guidance from the Attorney General.
FCPA Under Fire: What Companies Need To Consider After Trump's Executive Order
CM Crowell & Moring LLP More Our founders aspired to create a different kind of law firm when they launched Crowell & Moring in 1979. From those bold beginnings, our mission has been to provide our clients with the best services of any law firm in the world through a spirit of trust, respect, cooperation, collaboration, and a commitment to giving back to the communities around us.
"Help Wanted": Justice Department Debuts Its Corporate Whistleblower Awards Pilot Program
On August 1, 2024, Deputy Attorney General Lisa Monaco unveiled the Department of Justice's new Corporate Whistleblower Awards Pilot Program. The announcement marks the conclusion of the Department's previously announced "sprint" towards a pilot program, as DAG Lisa Monaco first previewed back in March of this year.
Updated DOJ Guidance Keeps Compliance in the Spotlight
On Friday, the Department of Justice released an updated version of its Evaluation of Corporate Compliance Programs (“ECCP”) guidance—the latest in a series of updates to the administration’s approach to corporate criminal resolutions, and the first substantive update to the ECCP guidance since June 2020.
Did the DOJ just narrow the path to declinations?
The January 2023 revisions to DOJ’s Corporate Enforcement Policy for the first time spelled out the factors that allow a company to qualify for a declination even in the presence of aggravating circumstances. This change has been touted alongside other significant revisions to the Policy—including increased penalty reductions in certain scenarios—as providing further encouragement for companies to self-disclose misconduct.
Supply Chain Pressures Trigger Escalating FCPA Risks - Impact on Retailers
A perfect storm of unprecedented stress on the global supply chain from the continuing COVID-19 pandemic coupled with the promise of increased FCPA enforcement by U.S. regulators makes this an opportune time for retailers to take stock of changes to their corruption risk profile and ensure that they adjust their compliance programs accordingly.
Revisions to DOJ’s Corporate Compliance Guidance Indicate that a Dynamic, Data-Driven and Well-Resourced Compliance Program is More Important than Ever | LexBlog
On Monday, June 1, 2020, the Department of Justice’s (DOJ’s) Criminal Division issued an updated version of the “Evaluation of Corporate Compliance Programs” guidance. The guidance was originally published by the Criminal Division’s Fraud Section in February 2017, and last revised in April 2019.
SEC Warns Against Insider Trading Risks from Pandemic Fallout
On March 23, 2020, the co-directors of the SEC’s Division of Enforcement, Stephanie Avakian and Steve Peikin, issued an unambiguous warning against insider trading and other illegal practices stemming from the COVID-19 fallout.
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