And no one expects a target letter. The Department of Justice defines a “target” of federal criminal investigation as “a person as to whom the prosecutor or the grand jury has substantial evidence linking him or her to the commission of a crime and who, in the judgment of the prosecutor, is a putative defendant.” Federal prosecutors are encouraged to notify targets of their status and give them a chance to testify before the grand jury when such notification won’t compromise the integrity of the government’s investigation—such as by prompting the target to flee the jurisdiction or destroy evidence. When they’re given, those notifications are known as target letters.

We want our clients to avoid getting those target letters. That starts with great compliance programs and robust internal controls to avoid fraud and other malfeasance. It also takes rigorous and sensitive internal investigations to determine whether there’s a problem. If the government begins its own investigation, potential white collar defendants need careful counsel to avoid enforcement action, which can take the form of civil, criminal, and administrative proceedings, and to achieve the best possible outcome in any enforcement action that does ensue.

Target Letter—published by our Investigations, Compliance & White Collar Team—is a resource for those who are in need of practical information and valuable insights covering a broad range of government investigations and state and federal criminal and civil proceedings. We’ll focus particularly on gathering news and providing analysis of white collar issues related to healthcare, government contracting, technology, money laundering, corruption, and fraud and enforcement developments in the Pacific Northwest.  Because no one expects the Spanish Inquisition . . . .

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ICW Team

Our Investigations, Compliance and White Collar Team represents individuals and corporations in a broad range of government investigations and state and federal criminal and civil proceedings.

Areas of special emphasis include:

  • White-collar criminal and civil defense from investigation through trial,
  • Internal investigations and audits triggered by regulatory enforcement actions,
  • Investigations to assess regulatory compliance, and
  • Compliance programs to address newly promulgated regulations.

Our team members frequently appear before courts and agencies throughout the country in a wide variety of matters and at all stages of proceedings. We represent subjects and targets of investigations and prosecutions, as well as witnesses in matters involving allegations of:

  • Health care and other government program and procurement fraud,
  • Conspiracy,
  • Tax evasion,
  • Improper payments to foreign governments,
  • Computer crime,
  • Money laundering,
  • Bank and bankruptcy fraud,
  • Antitrust,
  • Unfair or deceptive trade practices,
  • Securities fraud,
  • Mail and wire fraud, and
  • Prescription drug diversion and related record-keeping failures.

An effective white-collar practice requires collaboration with attorneys in many different fields. Our ability to draw from the firm’s related experiences in taxation, immigration, securities, health care and civil litigation permit us to assemble a powerful defense team, often led by former federal and state prosecutors and regulators. Indeed, the group has been highly ranked in the U.S. News and Best Lawyers annual “Best Law Firms” survey for work defending white-collar matters.

On the regulatory compliance side — both in response to government enforcement action and to proactive and reactive client requests — our attorneys often lead high-stakes internal investigations, fraud and abuse audits, sensitive background investigations, and forensic financial and other analyses. We also have considerable experience designing compliance programs to address claimed shortcomings and “findings” identified by internal or external business operations reviews.