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DOJ’s Criminal Division Turns Page on White Collar Crime—But Keeps One Foot in the Past

On May 12, 2025, the DOJ announced a new “white-collar enforcement plan” identifying new corporate enforcement priorities and aiming to promote greater focus, fairness and efficiency in prosecuting corporate misconduct. In a...more

Analyzing the Attorney General’s FCPA Enforcement Shift

UPDATE: President Signs Executive Order Directing DOJ to Pause All FCPA Enforcement for 180 Days - On February 10, 2025, President Trump issued an Executive Order directing the U.S. Department of Justice (DOJ) to pause all...more

New DOJ Focus on Executive Compensation in Resolving Criminal Investigations

Key Points - The DOJ recently announced several policy updates tethering resolution of criminal investigations to a company’s compensation and bonus programs. These updates include executive compensation focused...more

DOJ Focuses on Corporate Crime Involving Sanctions Evasion, Export Controls Violations and Similar Economic Crimes

Key Points - On March 2, 2023, DOJ announced that its NSD would hire more than 25 new prosecutors to investigate and prosecute sanctions evasion, export controls violations and similar economic crimes. Consistent with...more

DOJ Criminal Division Announces New Round of Revisions to Corporate Enforcement Policy

Key Points - On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. announced revisions to the DOJ Criminal Division’s corporate enforcement policy that offer new incentives to self-disclose corporate...more

Deputy AG Announces Significant Changes to DOJ Policies Regarding Corporate Investigations

Key Points - On September 15, 2022, Deputy AG Lisa O. Monaco released a Memorandum and provided remarks announcing several DOJ policy changes to prioritize and strengthen the Department’s prosecution of corporate crime....more

DOJ Assistant FCPA Chief Discusses “Meat-and-Potatoes” Cases, a “Global Awakening” and the Impact of New Technologies on...

• The prosecution of individuals remains a key priority for DOJ FCPA enforcement actions. • DOJ is “busier than ever,” focused on “higher-priority,” “bread-and-butter,” and “meat-and-potatoes” cases. • There is no...more

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