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Recent Sanctions Enforcement Actions Demonstrate Importance of  Incorporating All Available Data into Screening

For U.S. businesses, sanctions compliance has never been more challenging or more important. The U.S. has responded to Russia’s invasion of Ukraine with a broad range of sanctions targeting the Russian government, its...more

New Incentives Added to the Criminal Division’s Corporate Enforcement Policy

On January 17, 2023, Assistant Attorney General (AAG) Kenneth A. Polite, Jr. delivered remarks to an audience at the Georgetown University Law Center, announcing changes to the Criminal Division’s Corporate Enforcement Policy...more

Brazilian Airline to Pay Millions in Coordinated Foreign Bribery Resolution

On September 15, 2022, GOL Linhas Aéreas Inteligentes S.A. (GOL), Brazil’s second largest domestic airline, resolved long-running parallel investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange...more

Department of Justice Criminal Chief Points to Prevention as Key Aspect of Corporate Compliance

The Assistant Attorney General and head of the Department of Justice’s Criminal Division recently sat for an interview with the Wall Street Journal where he provided important insight into the Department’s increased focus on...more

DOJ Publishes FCPA Declination on Cross-Border Bribery Investigation

Without fanfare, DOJ recently published a “declination and disgorgement letter,” the first FCPA declination published by the Department since August 2020. As disclosed in the letter, DOJ has declined to prosecute Jardine...more

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