In a long overdue move to fill a perceived gap in U.S. law, this year’s National Defense Authorization Act included a new law that will finally criminalize the solicitation of bribes by foreign officials....more
It is one of the hardest questions a company can face: after discovering criminal conduct inside your company, do you self-report to the government or not? If you can quickly and quietly fix the problem, then you may be able...more
10/13/2023
/ Corporate Misconduct ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Disgorgement ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
Internal Investigations ,
Safe Harbors ,
Self-Reporting ,
White Collar Crimes
Earlier this month, a federal judge vacated two convictions related to the Department of Justice’s (“DOJ”) investigation into corruption in international soccer, widely known as the “FIFA Case.” Despite the jury’s findings...more
10/2/2023
/ Anti-Corruption ,
Bribery ,
Department of Justice (DOJ) ,
Enron ,
Fédération Internationale de Football Association (FIFA) ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Honest Services Fraud ,
Kickbacks ,
Soccer ,
Travel Act ,
Wire Fraud
In an apparent response to a downturn in corporate cases and criticism that its harsh rhetoric was chilling corporate cooperation, the Department of Justice (“DOJ”) recently announced significant changes to its policy on...more
Enforcement of corporate crimes, which languished for two years during the COVID-19 pandemic, will grow more vigorous this year and may be accompanied by significantly tougher penalties, partners with Vinson & Elkins’ (“V&E”)...more
5/27/2022
/ Anti-Corruption ,
Bribery ,
Coronavirus/COVID-19 ,
Cryptocurrency ,
Cyber Crimes ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FBI ,
Foreign Corrupt Practices Act (FCPA) ,
Ransomware ,
Securities and Exchange Commission (SEC) ,
Special Purpose Acquisition Companies (SPACs) ,
White Collar Crimes
A review of President Biden’s proposed Budget (“Budget”) for 2023 spotlights the enforcement priorities of the president’s Justice Department as the administration enters its third year. ...more
4/21/2022
/ Antitrust Division ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Crime Victims ,
Cybersecurity ,
Department of Justice (DOJ) ,
Environmental Justice ,
Environmental Protection Agency (EPA) ,
Federal Budget ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Joe Biden ,
Popular ,
Procurement Collusion Strike Force ,
Securities and Exchange Commission (SEC) ,
The Clayton Act
In a dramatic departure from prior practice, the U.S. Department of Justice (“DOJ”) recently released its first Opinion Procedure Release (“OPR”) in over eight years, and perhaps responding to criticism from the business...more
With the holiday season upon us, companies waiting for a nice surprise this Christmas are more likely to find a lump of coal in their stocking. In a series of recent announcements, Department of Justice (“DOJ”) officials have...more
A new sheriff is in town — and that means the potential for big changes ahead for white-collar criminal enforcement in terms of specific areas of focus and volume of investigations...more
6/25/2021
/ Attorney General ,
Biden Administration ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Environmental Justice ,
Federal Trade Commission (FTC) ,
Foreign Corrupt Practices Act (FCPA) ,
No-Poaching ,
White Collar Crimes
On June 25, 2020, Novartis AG, a Swiss multinational pharmaceutical company, and two subsidiaries reached a combined $345 million resolution with the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange...more
7/16/2020
/ Bribery ,
Cease and Desist Orders ,
Corporate Counsel ,
Department of Justice (DOJ) ,
DPA ,
Foreign Corrupt Practices Act (FCPA) ,
Health Care Providers ,
Novartis ,
Pharmaceutical Industry ,
Popular ,
Securities and Exchange Commission (SEC) ,
Vietnam
On July 3, 2020, the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) published the Second Edition of “FCPA: A Resource Guide to the U.S. Foreign Corrupt Practices Act” (the “Guide”)....more
In a novel and aggressive move likely aimed at garnering goodwill with federal regulators, Venezuelan state-owned entity CITGO Petroleum Company (“CITGO”) has sued its former agent for harm CITGO alleges was caused by the...more
6/4/2020
/ Asset Recovery ,
Bribery ,
Citgo ,
Crime Victims ,
Criminal Liability ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Oil & Gas ,
Popular ,
Venezuela
On April 14, 2020, for the first time, the Department of Justice (“DOJ”) published a list identifying all corporate monitors actively engaged by companies as a part of criminal resolutions with the Criminal Division’s Fraud...more