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Business Impacts of Trump’s Executive Order Pausing FCPA Enforcement

On February 10 President Trump issued an Executive Order, Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security, signaling a shift in U.S. enforcement priorities regarding...more

Implications of DOJ’s New Safe Harbor for Disclosing Misconduct Uncovered During M&A Transactions

U.S. Deputy Attorney General Lisa Monaco recently announced that the Department of Justice (DOJ) is adopting a new safe harbor policy to incentivize corporations to voluntarily self-disclose criminal misconduct discovered...more

What Every Multinational Company Should Know About … Anti-Corruption

The international trade and regulatory environment never has been more difficult for multinational corporations to navigate. For companies that operate, source from, or sell goods, software, or services across borders, legal...more

DOJ Issues New Corporate Compliance Guidance for Compensation Clawbacks and Messaging Apps

On March 3, 2023, the Department of Justice (DOJ) announced noteworthy updates to its Evaluation of Corporate Compliance Programs (ECCP) guidance. In remarks at the American Bar Association’s National Institute on White...more

Antitrust Division Announces Update to Its Leniency Program and Revamps Answers to Frequently Asked Questions

On April 4, 2022, the U.S. Department of Justice’s Antitrust Division released updated guidance on its Leniency Program, which protects companies and employees who cooperate with the government from prosecution for their...more

Reassessing Your Global Compliance Risk Profile

The unprecedented challenges created by the COVID-19 pandemic and resulting government lockdowns could strain even the most robust compliance programs. Companies have been appropriately focused on business preservation during...more

DOJ/SEC Release New Edition of FCPA Resource Guide

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

The Long Arm of American Enforcement: How Companies Without U.S. Operations Can Still Find Themselves Facing U.S. Law and...

...Think your company and its employees are beyond the reach of U.S. authorities? Maybe you don’t have U.S. operations there, or your company isn’t publicly traded on a U.S. stock exchange. Perhaps you don’t directly sell or...more

Charitable Giving, Government Support and Concession Requests, and Anti-Corruption Compliance in the Time of the Coronavirus...

The COVID-19 pandemic has created hardships across the globe at unprecedented levels – with practically no region or industry unaffected. Governments at all levels across the globe, along with non-governmental and...more

Internal Investigations and Privileges: Two More Courts Rule

Despite the global pandemic, the federal judiciary continues to issue rulings. In the last week, two courts provided guidance about when self-disclosures to the government waive the attorney-client privilege, underscoring the...more

FCPA Notebook: Trends in 2019

Foley & Lardner LLP’s International Government Enforcement Defense & Investigations team has created its latest FCPA infographic, which presents an overview of some high-level enforcement trends in an easy-to-view,...more

DOJ Announces Updated Guidance on Evaluating Corporate Compliance Programs

The U.S. Department of Justice (DOJ) has released updated guidance on evaluating corporate compliance programs. The Evaluation of Corporate Compliance Programs updates prior guidance that was released by DOJ in February 2017....more

DOJ Announces Changes to the Yates Memo Policy on Individual Accountability

On Thursday, November 29th, the U.S. Department of Justice (DOJ) announced changes to its policy known as the “Yates Memo.” That policy, established in 2015 by then-Deputy Attorney General Sally Yates, had required companies...more

DOJ Announces Policy to Promote Fairness Where Multiple Authorities Investigate the Same Misconduct

On May 9, 2018, the U.S. Department of Justice (DOJ) announced a policy related to resolutions of criminal and civil corporate enforcement. The new “Policy on Coordination of Corporate Resolution Penalties” was issued by...more

Diwali: An Opportune Time for an Anti-Corruption Compliance Reminder

This year, India celebrates Diwali on October 19, 2017. “The Festival of Lights,” as Diwali (or Deepavli) is commonly called, is celebrated across India with great aplomb, joy and, of course, delicious sweets. Diwali...more

DOJ Fraud Section Offers Super Credit in FCPA Pilot Program

This week, the Fraud Section of the Department of Justice (DOJ) announced a pilot program that extends additional “mitigation credit” to qualifying companies that “fully cooperate” in matters involving the Foreign Corrupt...more

Why It's Wise to Pay Attention to Your FCPA Compliance

Companies in the automotive industry would be wise to pay attention to Foreign Corrupt Practices Act (the “FCPA”) compliance. What has in the past been a risk management issue principally for massive multi-national...more

Top Legal Issues Facing Automotive Suppliers in 2015

Foley’s Automotive Industry Team has prepared this overview of the major trends we see affecting automotive suppliers this year. While not all legal risk can be anticipated, companies that are aware of litigation,...more

Alstom’s FCPA Guilty Plea and Fine of $772 Million Offer Compelling Lessons

The December 23, 2014, announcement by the U.S. Department of Justice (DOJ) that Alstom, S.A., a French power and transportation company, pled guilty to two Foreign Corrupt Practices Act (FCPA) charges and agreed to pay $772...more

Diebold Resolves FCPA Charges for $48 Million

On October 22, 2013, the U.S. Department of Justice (“DOJ”) and the Securities & Exchange Commission (“SEC”) announced their agreements with Diebold Inc. (“Diebold”) regarding probes into alleged bribery of foreign bank...more

Long-Anticipated FCPA Guidance Underscores Need for Effective FCPA Compliance

For 35 years, the U.S. government has enforced the Foreign Corrupt Practices Act (FCPA) while providing an incomplete picture of its views of either effective FCPA compliance or how certain key terms in the statute should be...more

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