On May 12, DOJ’s Criminal Division head, Matthew G. Galeotti, issued a memo to all Criminal Division personnel, entitled “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime,” to “outline the Criminal...more
Share on Twitter Print Share by Email Share Back to top On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to its Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). (See...more
In less than 100 days, the Trump administration has implemented a dizzying array of new tariffs, significantly increasing costs and complexity for U.S. importers. The administration is keenly aware that companies operating in...more
3/26/2025
/ China ,
Criminal Prosecution ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Statements ,
Foreign Trade Regulations ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Regulatory Requirements ,
Risk Management ,
Risk Mitigation ,
Smuggling ,
Tariffs ,
Trump Administration ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes ,
Wire Fraud
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
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
10/13/2023
/ Acquisitions ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Disgorgement ,
Due Diligence ,
Enforcement ,
Investigations ,
Mergers ,
Safe Harbors ,
Self-Disclosure Requirements
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
5/25/2023
/ Anti-Corruption ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Multinationals ,
Penalties ,
Risk Assessment ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
State-Owned Enterprises
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
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
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
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
...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
6/2/2020
/ Anti-Bribery ,
Anti-Competitive ,
Antitrust Violations ,
Business Operations ,
Conspiracies ,
Copyright ,
Department of Justice (DOJ) ,
Enforcement ,
Exports ,
Federal Trade Commission (FTC) ,
Foreign Corrupt Practices Act (FCPA) ,
Imports ,
International Trade Commission (ITC) ,
Jurisdiction ,
Office of Foreign Assets Control (OFAC) ,
Patents ,
Sherman Act ,
Trademarks
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
4/9/2020
/ Anti-Corruption ,
Centers for Disease Control and Prevention (CDC) ,
Charitable Donations ,
Compliance ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Eli Lilly ,
Enforcement ,
Fraud ,
Fraud and Abuse ,
Investment ,
Nu Skin ,
Risk Assessment ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
World Health Organization
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
4/2/2020
/ Board of Directors ,
Compliance ,
Continuing Legal Education ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Data Points ,
Department of Justice (DOJ) ,
Directors ,
Ethics ,
Internal Investigations ,
Securities and Exchange Commission (SEC)
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
10/9/2019
/ Anti-Corruption ,
Canada ,
CFTC ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Latin America ,
Self-Reporting ,
Strategic Enforcement Plan ,
White Collar Crimes
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
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
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
On November 29, 2017, Deputy Attorney General Rod Rosenstein announced that the U.S. Department of Justice (DOJ) was issuing a new enforcement policy covering its enforcement of the Foreign Corrupt Practices Act (FCPA). The...more
12/1/2017
/ Anti-Bribery ,
Attorney-Client Privilege ,
Audits ,
corp ,
Corporate Counsel ,
Corporate Criminal Fines ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Document Productions ,
FCPA Guidance ,
Federal Pilot Programs ,
Fifth Amendment ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Recordkeeping Requirements ,
Remediation ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
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
9/16/2017
/ Anti-Corruption ,
Compliance ,
Corporate Gifts ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Government Officials ,
India ,
Prevention of Corruption Act (PCA) ,
Public Officials ,
Public Servants ,
Securities and Exchange Commission (SEC)
Since mid-2000s investigation of Siemens, and the resulting $800 million penalty for violations of the Foreign Corrupt Practices Act (FCPA), the FCPA has been an enforcement priority of the U.S. Government. Although a dip in...more
5/12/2017
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Bribery ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Enforcement Actions ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
ISO ,
ISO 37001 ,
Regulatory Agencies ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
Whistleblower Protection Policies ,
Yates Memorandum
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
4/9/2016
/ Bribery ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Internal Investigations ,
Popular ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes ,
Yates Memorandum
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
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
1/12/2015
/ Americans with Disabilities Act (ADA) ,
Antitrust Provisions ,
Auto Parts ,
Automobile Recall ,
Automotive Industry ,
Department of Justice (DOJ) ,
Employer Liability Issues ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Manufacturers ,
NHTSA ,
NLRB ,
Suppliers ,
V2V
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
12/30/2014
/ Accounting Controls ,
Alstom ,
Bribery ,
C-Suite Executives ,
Corporate Counsel ,
Corporate Criminal Fines ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Indictments ,
Subsidiaries
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