We have previously written about the impact of the pause in enforcement of the FCPA implemented by the Trump Administration on non-American companies.1 Although the 180-day review period the Executive Order provided to the...more
4/29/2025
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
EU ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
UK
On February 20, 2025, the State Department designated multiple Mexican drug cartels and Transnational Criminal Organizations (“TCOs”) as foreign terrorist organizations (“FTOs”). At the same time, these groups were designated...more
4/1/2025
/ Cartels ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Fraud ,
Mexico ,
Multinationals ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Management ,
Terrorist Financing ,
Whistleblowers
The State Department’s February 20, 2025, designation of specific Mexican drug cartels and Transnational Criminal Organizations (TCOs) as foreign terrorist organizations (FTOs) creates serious new risks for businesses...more
3/12/2025
/ Anti-Terrorism Financing ,
Cartels ,
Corporate Counsel ,
Corporate Crimes ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Florida ,
Mexico ,
National Security ,
New Jersey ,
Risk Management ,
Texas
How the New Law Creates Legal Risks and Opportunities for International Businesses -
On December 22, 2023, President Biden signed into law the 2024 National Defense Authorization Act (NDAA), which will give the U.S....more
1/5/2024
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Department of Justice (DOJ) ,
Enforcement ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
NDAA ,
Popular ,
Securities Exchange Act of 1934 ,
Travel Act ,
Wire Fraud
Generative AI has captured the world’s attention, and regulators are no exception. Indeed, the FTC and other regulators are increasingly active on multiple fronts—from large scale antitrust enforcement efforts, to issues as...more
To close out 2021, enforcement authorities throughout the Americas continued to investigate fraud, corruption, and other misconduct across the region. For 2022, we expect an uptick of anticorruption investigations as a...more
3/4/2022
/ Anti-Corruption ,
Anti-Money Laundering ,
Biden Administration ,
Corporate Counsel ,
Corruption ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
El Salvador ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Guatemala ,
Honduras ,
Latin America ,
OECD
On October 3, the International Consortium of Investigative Journalists began reporting on millions of confidential documents relating to the financial activities of heads of state, international business leaders, and other...more
This summary is part of our regular reporting of trends and developments related to investigations and enforcement activity into fraud, corruption, and other misconduct by authorities in the United States and the Americas and...more
8/9/2021
/ Anti-Corruption ,
Austria ,
Banks ,
Biden Administration ,
Brazil ,
Bribery ,
DEA ,
Department of Justice (DOJ) ,
Enforcement Actions ,
EU ,
FBI ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Guatemala ,
Investigations ,
Latin America ,
Mexico ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
UK
DOJ Enforcement in Latin America Continues Despite Pandemic -
During the 3rd quarter, the Department of Justice made a number of high-profile arrests and concluded plea agreements in several cases related to Latin...more
11/24/2020
/ Anti-Corruption ,
Anti-Money Laundering ,
Appeals ,
Bribery ,
Department of Justice (DOJ) ,
Embezzlement ,
Extradition ,
Foreign Corrupt Practices Act (FCPA) ,
Latin America ,
Mexico Supreme Court of Justice ,
Money Laundering ,
National Security Agency (NSA)
In this October edition, we are delighted to present legal and industry updates from the firm’s global network of offices. The selection is based upon our experience of the wide variety of issues
faced by our clients in...more
On June 1, 2020, the U.S. Department of Justice (“DOJ”) released updated guidance entitled “Evaluation of Corporate Compliance Programs” (“Updated Guidance”), which provides the DOJ Criminal Division’s views on what comprises...more
Energy Explosion: 10 Trends to Watch in Energy Restructuring -
On April 20, 2020, U.S. benchmark crude traded negative for the first time. This drastic drop in price was caused by the perfect storm of the Saudi...more
5/20/2020
/ Carbon Off-Set Credits ,
Coronavirus/COVID-19 ,
Energy Sector ,
Foreign Investment ,
Mexico ,
Natural Gas ,
Oil & Gas ,
Power Infrastructure ,
Renewable Energy ,
Russia ,
Saudi Arabia ,
Sustainability ,
Testimony
Enforcement authorities throughout the United States and Latin America are grappling with the impact of the COVID-19 pandemic, which is dramatically changing the economic landscape and is sure to change the enforcement...more
In the fourth quarter of 2019, U.S. enforcement authorities sustained efforts to prosecute individuals violating U.S. anticorruption laws in matters related to Latin America, while authorities in Latin America, including in...more
1/22/2020
/ Anti-Corruption ,
Asset Seizure ,
Brazil ,
Bribery ,
Corruption ,
Criminal Convictions ,
Criminal Investigations ,
Criminal Liability ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Enforcement Authority ,
Export Controls ,
Financial Crimes ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Guilty Pleas ,
Legislative Vetoes ,
Mexico ,
Peru ,
Sanction Violations ,
Statutory Authority ,
Voluntary Disclosure
Enforcement authorities throughout the United States and the Americas continue to aggressively investigate fraud and corruption across the region in the third quarter of 2019. Below, we highlight some recent developments and...more
10/14/2019
/ Airlines ,
Anti-Corruption ,
Argentina ,
Aviation Industry ,
Brazil ,
Bribery ,
Chile ,
Compliance ,
Corporate Investigations ,
Corruption ,
Criminal Convictions ,
Criminal Penalties ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Ecuador ,
Enforcement Authority ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Government Investigations ,
Indictments ,
Kickbacks ,
Latin America ,
Mexico ,
Money Laundering ,
Peru ,
Popular ,
Securities and Exchange Commission (SEC) ,
United States-Mexico-Canada Agreement (USMCA)
Significant Changes to FERC’s Rules for Market-Based Rate Sellers -
On July 18, 2019, the Federal Energy Regulatory Commission (“FERC”) issued two orders modifying its rules for sellers to obtain or retain authorization...more
The U.S. Justice Department, the U.S. Securities and Exchange Commission, and their enforcement partners throughout Latin America remain focused on actively investigating corruption activities and bringing enforcement actions...more
7/1/2019
/ Anti-Corruption ,
Brazil ,
Chief Compliance Officers ,
Compliance ,
Corruption ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement ,
FBI ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Latin America ,
Medical Devices ,
Mexico ,
Pharmaceutical Industry ,
Self-Disclosure Requirements
Argentina’s corruption notebooks scandal is just as it sounds—a scandal initiated by eight notebooks documenting at least seven years of elaborate corruption schemes involving senior officials in Argentina’s government. The...more
Major FCPA Enforcement Action -
Including charges against the CEO and CFO for failing to prevent misconduct -
In one of the largest FCPA settlements in history, hedge fund Och-Ziff Capital Management Group LLC...more
12/23/2016
/ CEOs ,
Democratic Republic of Congo ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Hedge Funds ,
Japan ,
Libya ,
Och-Ziff ,
Penalties ,
Securities and Exchange Commission (SEC) ,
Settlement
In one of the largest FCPA settlements in history, hedge fund Och-Ziff Capital Management Group LLC (“Och-Ziff”) recently resolved a long-running government inquiry by agreeing to $413 million in financial penalties and a...more
10/10/2016
/ Africa ,
Bribery ,
Deferred Prosecution Agreements ,
Democratic Republic of Congo ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Hedge Funds ,
Internal Controls ,
Investment ,
Libya ,
Och-Ziff ,
Popular ,
Private Equity Funds ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
Sovereign Wealth Funds