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Future of FCPA Enforcement Uncertain (For Now) as New Administration Revamps the Law Enforcement Toolkit

Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more

DoD Releases Final CMMC Program Rule, Formally Initiating Its Cybersecurity Program

On October 15, 2024, the Department of Defense (“DoD”) released its final rule (the “Final Rule”) formally establishing the Cybersecurity Maturity Model Certification (“CMMC”) program, nearly three years after first...more

DOJ and SEC Tout Parallel Objectives Regarding Individual Accountability, Timely Disclosure, and More

Deputy Attorney General Lisa A. Monaco’s September 15, 2022 memorandum (the “Memo”) clarified a series of Department of Justice (“DOJ”) objectives regarding corporate and individual responsibility that parallel recent...more

DOJ Chooses Sticks Over Carrots: Three Reasons Why Changes to DOJ’s Corporate Enforcement Policy May Chill Cooperation by...

In announcing recent changes to its corporate criminal enforcement policies, the Department of Justice (“DOJ” or the “Department”) continued its forceful “tough on crime” initiatives to deter wrongdoing....more

Why Voluntary Independent Compliance Monitorships Are Growing in Popularity

When companies get into trouble, it’s common practice for the government to call on independent third parties to help clean up the mess. Companies under investigation by the Department of Justice (“DOJ”) often agree to...more

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