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President Trump Orders FCPA Freeze; DOJ Announces Major Policy Realignment De-Emphasizing Corporate Investigations and Enforcement

The much-heralded end to prosecutions brought pursuant to the Foreign Corrupt Practices Act (FCPA) never materialized during the first Donald Trump administration, but Trump 2.0 has the potential to bring major change to the...more

DOJ Releases Its First FCPA Advisory Opinion Since 2014—What You Need to Know About the FCPA Advisory Opinion Process

For the first time since 2014, the Department of Justice’s (DOJ) Foreign Corrupt Practices Act (FCPA) Unit has issued an opinion responding to a request for advice on compliance with the anti-bribery provisions of the FCPA. ...more

DOJ and SEC Issue First Major Update to FCPA Resource Guide Since 2012: What You Need to Know

INTRODUCTION - On 3 July 2020, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) released the second edition of the Resource Guide to the U.S. Foreign Corrupt Practices Act (Resource...more

DOJ Revises Corporate Compliance Guidance Calling Attention to Three Areas Where Most Companies Fall Short: Risk Assessments,...

On April 30, 2019, the U.S. Department of Justice (“DOJ”) Criminal Division revised its Evaluation of Corporate Compliance Programs Guidance Document (the “2019 Guidance”) to assist prosecutors in evaluating the effectiveness...more

Takeaways from the 34th International Conference on the Foreign Corrupt Practices Act

At the 34th International Conference on the Foreign Corrupt Practices Act held last week in Washington, D.C., industry executives, members of the defense bar, and regulators examined developments in the enforcement of the...more

The New Faces of FCPA Enforcement: The Transition to a Sessions-Clayton Enforcement Regime Is Unlikely to Result in Drastic...

Now that the Trump administration has passed its first 100 days, some additional insights are available with respect to how the administration plans to enforce anti-corruption laws, including the Foreign Corrupt Practices Act...more

Sapin II - France’s War on Corruption

In July 2015, Michel Sapin, the French Minister of Finance, summarized his proposals for a new French law prohibiting corruption and seeking “transparency in economic life”. That law, modeled after the U.S. Foreign Corrupt...more

FCPA Enforcement Under Trump: Don’t Call Off the Cavalry Just Yet

Despite President-elect Donald Trump’s past negative comments about the Foreign Corrupt Practices Act (“FCPA”), companies should continue to take FCPA compliance seriously and employ best practices. Indeed, ethical business...more

The First Ninety Days of the FCPA Unit’s Pilot Program

On April 5, 2016, the Department of Justice (“DOJ”) introduced a yearlong “Pilot Program” to guide the conduct of investigations and prosecutions pursuant to the Foreign Corrupt Practices Act (“FCPA”). Announced by Assistant...more

DOJ and SEC Representatives Tackle Pressing Anti-Corruption Issues in 2014

On March 20th and 21st, U.S. regulators, practioners, and other anti-corruption industry professionals gathered in Washington, D.C. for the Second Annual Global Anti-Corruption Congress. The Congress featured speakers,...more

What Do Federal Authorities Expect of Companies Subject to the FCPA?

In mid-November 2012, federal authorities released their much-anticipated ”FCPA: A Resource Guide to the U.S. Foreign Corrupt Practices Act,” prepared jointly by the Justice Department’s Criminal Division and the Enforcement...more

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