Whether cartels do or do not qualify as “instrumentalities of a government” under current FCPA law or based on the AG’s forthcoming revised FCPA guidance, their entanglement with corrupt officials and influence over local...more
With the second Trump administration holding the reins of the executive branch, companies should brace for a renewed focus on trade enforcement. The administration has already begun to expand tariffs on a variety of items...more
President Donald Trump recently released an executive order temporarily halting Foreign Corrupt Practices Act investigations and enforcement actions....more
Newly Appointed US Attorney General Pam Bondi issued a directive shifting the focus of Foreign Corrupt Practices Act investigations and cases away from those that do not involve criminal operations of cartels and...more
The US House of Representatives passed a bill on November 12, 2024 that would enhance federal efforts to implement a new supply-chain security enforcement initiative. The bipartisan bill seeks to strengthen the role and...more
The US Department of Justice’s (DOJ) Criminal Division on August 1 announced the details of its much-anticipated Corporate Whistleblower Awards Pilot Program. This three-year initiative aims to incentivize individuals to...more
The US Department of Justice’s recent prosecution of Cambridge International Systems Inc. illustrates its ongoing pursuit of corporate criminal enforcement in the defense arena....more
The US Court of Appeals for the DC Circuit held that EPA’s interpretation that emissions controls under Section 111 of the Clean Air Act must be limited to those that can be applied “at” and “to” a stationary source was...more