The Justice Department at the time declined to release a complete list of defendants’ names. Bloomberg identified the George W. Bush-era charges from a sample list of eight cases that the department did provide. In 10 more cases that individual U.S. attorneys’ offices publicized in news releases as being part of the initiative, Bloomberg found that six of them were filed in 2009 and 2010, before the initiative began.

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Ryan Chittum is a former Wall Street Journal reporter, and deputy editor of The Audit, CJR's business section. If you see notable business journalism, give him a heads-up at rc2538@columbia.edu. Follow him on Twitter at @ryanchittum.