January 06, 2026
In a recent Law360 article, Foley Hoag partner David G. Lazarus discussed several areas of growing enforcement risk.
Speaking on unlicensed money transmitting investigations, Lazarus explained that these probes “can be very broad, and it’s a tool the government uses…to follow the flow of money in the U.S. to bad actors overseas,” noting that the DOJ “seem[s] to be using it with increasing frequency.”
Addressing politically charged prosecutions, Lazarus added, “It does not appear that the department will shy away from future political investigations and prosecutions because of any perceived stumblings or obstacles.”
He also highlighted the skin substitute space, saying, “Expect to see next year an uptick in investigations…ranging from medical-necessity investigations to upcoding or charging for more pieces of skin substitute than were actually utilized.”
