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DOJ declines prosecution for PE firm after post-acquisition voluntary self-disclosure

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) and the US Attorney’s Office for the Southern District of Texas announced the first declination of prosecution for an acquirer that...more

OFAC sanctions and FinCEN Advisory target Iran’s shadow banking infrastructure

On June 6, 2025, the US Department of the Treasury’s (Treasury) Office of Foreign Assets Control (OFAC) sanctioned over 30 individuals and entities believed to be tied to a network that laundered billions of dollars on behalf...more

DOJ releases new corporate crime enforcement guidance, telling companies what to expect—and how to avoid criminal penalties

On May 12, 2025, the US Department of Justice’s (DOJ) Criminal Division issued a memorandum titled Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime (the Memo) to all Criminal Division personnel. The...more

Executive Order signals major shift in FCPA enforcement—for now

President Trump’s February 10, 2025 Executive Order pausing Foreign Corrupt Practices Act (FCPA) enforcement and ordering an overhaul of FCPA policy marks a significant shift by the Department of Justice (DOJ), at least in...more

New Department of Justice policy directives outline shift in enforcement priorities

On February 5, 2025, the US Department of Justice (DOJ) issued two memoranda, General Policy Regarding Charging, Plea Negotiations, and Sentencing and Total Elimination of Cartels and Transnational Criminal Organizations,...more

DOJ cracks down on data transfers

Proposed rule would create new prohibitions on transactions of sensitive personal data and government-related data - The Department of Justice (DOJ) has proposed a new rule aimed at preventing access of China and other...more

DOJ emphasizes importance of AI risk mitigation, whistleblower protections, and clawback compensation policies

Last Monday, the Department of Justice (the DOJ or the Department) announced significant updates to the DOJ Criminal Division’s Evaluation of Corporate Compliance Programs (ECCP). These updates discuss, for the first time,...more

More carrots, more sticks - DOJ announces agency-wide whistleblower pilot program

The Department of Justice has announced yet another pilot program, adding to their “mix of carrots and sticks” designed “to promote responsible corporate citizenship.” The new whistleblower pilot program, which is still under...more

SDNY announces new whistleblower program, continuing Justice’s push for self-disclosure

“Call us before we call you.” With this message, on January 10, 2024, the Southern District of New York announced the SDNY Whistleblower Pilot Program (Pilot Program), which seeks to encourage individual participants in...more

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