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Future of FCPA Enforcement Uncertain (For Now) as New Administration Revamps the Law Enforcement Toolkit

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

New Year and New Administration: DOJ Races to Clear Its FCPA Docket Before the Trump Administration Begins

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

World Bank Group’s Watchful Eye: A Reminder of How Minor Ethical Breaches Can Result in Major Problems

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

Holiday Jeers: How The Grinch at DOJ May Make It Harder for Companies to Stay on the Nice List This Christmas

With the holiday season upon us, companies waiting for a nice surprise this Christmas are more likely to find a lump of coal in their stocking. In a series of recent announcements, Department of Justice (“DOJ”) officials have...more

FCPA Liability: Texas Federal Court Finds No Jurisdiction Over Foreign National Under Agency Theory

On November 10, 2021, the United States District Court for the Southern District of Texas granted a motion to dismiss Foreign Corrupt Practices Act (“FCPA”) charges brought against a Swiss resident and citizen, rejecting the...more

Congress Expands The Scope Of Anti-Money Laundering Rules—Disclosing Beneficial Owners Now Required

The National Defense Authorization Act for FY 2021 (“NDAA”) passed Congress on December 11, 2020, with a “veto-proof” margin. Included within the NDAA are a number of anti-money laundering provisions with import for companies...more

Venezuela’s CITGO Joins Other Companies And State-Owned Entities Seeking To Claim Victim Status And Restitution In FCPA Cases

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

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