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FCPA Compliance Report

FCPA Compliance Report: Mike Huneke and Brent Carlson with US Attorney David Metcalf

In this episode, Tom Fox cross-posts an episode of Red Flag Rising featuring U.S. Attorney for the Eastern District of Pennsylvania David Metcalf, joined by co-hosts Mike Huneke and Brent Carlson.

David Metcalf, the U.S. Attorney for the Eastern District of Pennsylvania, brings a practical, business-aware perspective on fraud enforcement and corporate compliance, shaped by experience both in government and as in-house counsel. He notes that white-collar enforcement in his district centers heavily on healthcare fraud but also extends to cybercrime, narcotics trafficking, export controls, and other complex investigations. Metcalf strongly encourages companies to consider self-disclosure in their self-interest, warning that the DOJ will be especially aggressive toward those that do not come forward. At the same time, he stresses that early engagement is the most effective approach, because trust and candid discussion at the outset can create meaningful benefits, including even unpublicized declinations.

 Key highlights:

  • Risk-based compliance shaped by business realities
  • Whistleblower evidence versus compliance rationale perspective
  • Data Analytics-Powered National Fraud Detection Center
  • Data-Driven Detection of Healthcare Fraud Cases
  • Tariff Evasion and Customs Fraud Crackdown
  • DOJ’s relaxed near-miss voluntary disclosure incentive

Resources:

More about U.S. Attorney David Metcalf

The Eastern District of Pennsylvania’s White Collar Justice Program

The DOJ’s National Fraud Enforcement Division

More about the 1950 classic Japanese film “Rashomon”

Contact Brent: brent@redflagsrising.com

More about Brent

Connect with Brent on LinkedIn

Contact Mike: michael.huneke@morganlewis.com

More about Mike

Connect with Mike on LinkedIn

Tom Fox

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