Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more
As we approach Inauguration Day on January 20, 2025, one question among anticorruption practitioners is how the Trump administration will handle enforcement of the Foreign Corrupt Practices Act (“FCPA”). In the meantime, we...more
12/23/2024
/ Anti-Corruption ,
Bribery ,
Corporate Crimes ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Popular ,
Securities and Exchange Commission (SEC) ,
Trump Administration
On October 7, 2024, the U.S. Supreme Court declined to hear a case concerning the “willfulness” element of the Anti-Kickback Statute (the “AKS”). This decision leaves intact a recent Second Circuit holding, which established...more
10/11/2024
/ Anti-Kickback Statute ,
Bribery ,
Corruption ,
Denial of Certiorari ,
False Claims Act (FCA) ,
Federal Contractors ,
Healthcare Fraud ,
Illegal Gratuities ,
Incentives ,
SCOTUS ,
Whistleblowers ,
White Collar Crimes
While much attention is given to compliance with applicable laws, such as the U.S. Foreign Corrupt Practices Act of 1977, many companies working on projects sponsored by Multi-Lateral Development Banks (“MDBs” or “MDB”)...more
Mere months after Airbus entered into a record-breaking, nearly $4 billion resolution with the U.S., U.K., and France to settle foreign bribery allegations, the U.K.’s Serious Fraud Office (“SFO”) moved on July 30, 2020, to...more
In a novel and aggressive move likely aimed at garnering goodwill with federal regulators, Venezuelan state-owned entity CITGO Petroleum Company (“CITGO”) has sued its former agent for harm CITGO alleges was caused by the...more
6/4/2020
/ Asset Recovery ,
Bribery ,
Citgo ,
Crime Victims ,
Criminal Liability ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Oil & Gas ,
Popular ,
Venezuela