News & Analysis as of

Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) Enforcement

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The Supreme Court Made Its Rulings; Corporate Compliance Needs March On

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At the end of June, the U.S. Supreme Court issued major decisions on the enforcement power of the Securities and Exchange Commission, what does or doesn’t qualify as a bribe of government officials, and on federal judges’...more

Foley Hoag LLP

Foley Hoag 2024 White Collar Year In Preview Series

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The government had another busy year in 2023, investigating and prosecuting healthcare fraud cases on multiple fronts. Contending with the enormous healthcare crises of the now-concluded COVID-19 pandemic and the ongoing...more

Foley & Lardner LLP

Supreme Court Rules Bribery Law Doesn’t Criminalize Gratuities — How Does that Impact the Anti-Corruption Legal Landscape?

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On Wednesday, June 26, 2024, the United States Supreme Court issued a 6–3 decision in Snyder v. United States, overturning the jury conviction of an Indiana mayor under Title 18, Section 666, of the U.S. Code for accepting...more

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Sanctions are the “New” FCPA – How this Era of Enforcement Shapes Third-Party Risk Management

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In the summer of 2022, Deputy Attorney General Lisa Monaco – a veteran prosecutor and currently number two at the helm of the U.S. Department of Justice (DOJ) – began to describe the enforcement of sanctions regulations as...more

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more

Womble Bond Dickinson

DOJ Enhancing Its Sanctions Toolkit

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President Biden recently signed a foreign aid bill that will have significant implications for United States sanctions enforcement, specifically Section 206 of the International Emergency Economic Powers Act (50 U.S.C. 1705)...more

American Conference Institute (ACI)

[Event] 18th Annual Conference on Anti-Corruption - June 18th - 19th, London, United Kingdom

Hosted by the C5 Group, the 18th Annual Conference on Anti-Corruption London will bring together the brightest minds in anti-corruption and compliance to review the most pressing multi-jurisdictional enforcement updates...more

Guidepost Solutions LLC

A “Quick Guide” to Government Whistleblower and Voluntary Self-Disclosure Programs: Heed the Warning from DOJ to Strengthen...

The Department of Justice (DOJ) has sounded the alarm: an aggressive crackdown on corporate misconduct is imminent. With an enforcement program on the horizon, corporations must heed the warning and take proactive measures to...more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - May 9th - 10th, New York, NY

Hosted by the American Conference Institute, the 19th Annual FCPA & Anti-Corruption Conference for the Life Sciences Industry returns for another exciting year with carefully researched programming based on critical findings...more

Latham & Watkins LLP

DOJ Announces New Whistleblower Program

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DOJ unveils a new whistleblower incentive program to complement the Department’s continued efforts to encourage self-reporting of criminal violations. On Thursday, March 7, 2024, US Deputy Attorney General Lisa Monaco...more

Miles & Stockbridge P.C.

DOJ Provides a Contemporary Spin on ‘Wanted’ Posters: New Whistleblower Rewards Program Announced

U.S. Deputy Attorney General Lisa Monaco delivered keynote remarks March 7 at the American Bar Association’s 39th National Institute on White Collar Crime. Emphasizing the need for a culture of compliance, Monaco highlighted...more

Bracewell LLP

Lifting the Fog on the Foreign Corrupt Practices Act: Enforcement and Compliance Trends to Watch in San Francisco

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As lawyers, corporate executives and federal law enforcement officials prepare to gather this week in San Francisco for the ABA’s 39th National Institute on White Collar Crime, we offer our takeaways from January’s Houston...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

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Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – December 2023 Update

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December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more

Morrison & Foerster LLP

2024 Regulatory, Compliance, and Enforcement Predictions for Life Sciences Companies

The year 2023 was a busy one for regulatory, compliance, and enforcement developments in the healthcare and life sciences industries, and 2024 promises to be even busier. We tapped MoFo’s Life Sciences + Healthcare Compliance...more

King & Spalding

Foreign Extortion Prevention Act (FEPA)

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How the New Law Creates Legal Risks and Opportunities for International Businesses - On December 22, 2023, President Biden signed into law the 2024 National Defense Authorization Act (NDAA), which will give the U.S....more

Bass, Berry & Sims PLC

FCPA Enforcement Update: Commodities Trader Agrees to Almost $100 Million Fine

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On December 14, the Department of Justice (DOJ) announced that Freepoint Commodities LLC, a Connecticut-based commodities trader, had agreed to a three-year deferred prosecution agreement (DPA) to resolve a DOJ investigation...more

Akin Gump Strauss Hauer & Feld LLP

7 Enforcement Predictions For US Export Controls, Sanctions

Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more

Foley & Lardner LLP

International Trade, Enforcement & Compliance Recent Developments Update (November 16, 2023)

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Did you know that whistleblowers can use the False Claims Act to get the U.S. Government to investigate allegations of lost revenue to the U.S. Treasury, including underpaid Customs tariffs? A large importer recently found...more

Bass, Berry & Sims PLC

FCPA Update: DOJ Opinion Procedure Releases Underscore That Payments to Officials Are Sometimes Permitted

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Two recent opinions released by the Department of Justice (DOJ) serve as a reminder that even under the strictly enforced Foreign Corrupt Practices Act (FCPA), payments to government officials are permissible in certain...more

ArentFox Schiff

Show Me the Money: Using Compensation Structures to Promote Compliance

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Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance. In the past few months, the DOJ has entered into settlement agreements that...more

American Conference Institute (ACI)

[Event] Practical Guide to FCPA Data Analytics - November 28th, National Harbor, MD

The U.S. Department of Justice, Criminal Division, updated its Evaluation of Corporate Compliance Program in March 2023, with renewed expectations for companies to use data analytics and testing. However, the government...more

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A Closer Look at the DOJ’s New M&A Safe Harbor Policy

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The Department of Justice announced for the first time a new safe harbor policy that will apply to mergers and acquisitions in cases where an acquiring company with an effective compliance program uncovers misconduct during...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - August 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Pillsbury Winthrop Shaw Pittman LLP

Voluntary Self-Disclosure: Is the Value Self-Evident?

How should companies think about DOJ, BIS and OFAC voluntary disclosure in the wake of the DOJ’s massive investment in sanctions and export control enforcement? The DOJ, BIS and OFAC released a joint compliance note...more

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