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Corporate Enforcement Actions for Kingpin Act Violations Highlight Cartel-Related Enforcement Risks

Since the February 20, 2025 designations of eight cartels and transnational criminal organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), many have discussed the...more

Customs and Tariff Fraud Enforcement Intensifies: DOJ Wields Mix of Tools to Target Trade Violations

As the Trump Administration’s America First trade policy and reciprocal trade agreements continue to take shape, the DOJ is gearing up for increased criminal and civil enforcement of customs and tariff violations. In the...more

DOJ Using Broad Civil Forfeiture Authority After Designating Cartels as Foreign Terrorist Organizations

On September 3, 2025, the US Department of Justice (DOJ) announced that it had seized 300,000 kilograms of precursor chemicals used to produce methamphetamine that had been shipped from China and were intended for clandestine...more

FCPA Update: DOJ Encourages US Companies to Report Corrupt Foreign Competitors

Although most reporting on the DOJ's latest Foreign Corrupt Practices Act (FCPA) guidelines has emphasized the anticipated reduction in overall anti-corruption enforcement, an equally important, but less noted, aspect has...more

DOJ Declines to Prosecute Private Equity Firm after Post-Acquisition Voluntary Self-Disclosure of Sanctions and Export Control...

In its first application of the policy on voluntary self-disclosures (“VSDs”) in connection with mergers and acquisitions (“M&A”), on June 16, 2025, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”)...more

DOJ Issues Promised FCPA Guidance: Decoding the Message

On June 10, 2025, the Department of Justice (“DOJ”) issued a memorandum establishing guidelines for enforcement of the Foreign Corrupt Practices Act (the “Guidelines” and “FCPA,” respectively). The DOJ issued the Guidelines...more

DOJ Already Filing Material Support Charges After Designating Cartels as Foreign Terrorist Organizations

On February 20, 2025, the United States designated eight cartels and transnational criminal organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). Since then, the US...more

DOJ Launches Civil Rights Fraud Initiative by Leveraging the False Claims Act: What Federal Fund Recipients Should Know

On May 19, 2025, Deputy Attorney General Todd Blanche announced the Department of Justice’s launch of a sweeping Civil Rights Fraud Initiative designed to hold federal contractors, grant recipients, and other federally funded...more

Ten Takeaways from the DOJ Criminal Division’s New Playbook on White Collar Enforcement Priorities

On May 12, 2025, the U.S. Department of Justice ("the DOJ" or "the Department") unveiled its new playbook for prosecuting white-collar and corporate crime. DOJ announced enforcement priorities for the Criminal Division ("the...more

SEC Enforcement 2.0: Chairman Atkins Has Arrived

Paul Atkins has taken the reins of the US Securities and Exchange Commission (SEC). After being confirmed by the Senate on April 9, Atkins officially began his tenure as SEC Chairman on April 21. His arrival is expected to...more

A new sheriff in town? No time for complacency as the US pauses anti-corruption enforcement

A new anti-bribery and corruption alliance among enforcement authorities in the UK, France and Switzerland sends a clear message to corporates that any pause in enforcement of the US FCPA does not mean that acts of bribery by...more

United States Designates Eight Cartels and Transnational Criminal Organizations

Effective February 20, 2025, the United States Designated Eight Cartels and Transnational Criminal Organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs)....more

DOJ Implements Major Changes to National Security Priorities

On February 5, 2025, President Trump's nominee to lead the Justice Department (the "Department"), Pamela Bondi, was confirmed by the Senate to serve as the U.S. Attorney General. Bondi immediately took action to reshape the...more

FCPA Freeze and Refocus: Is Enforcement Becoming a Tool to Promote U.S. Economic, Foreign Policy and National Security Interests?

On February 10, 2025, President Trump signed an executive order instructing the Attorney General of the United States to pause enforcement of the Foreign Corrupt Practices Act ("FCPA") and to issue updated guidelines for...more

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