The Department of Justice ("DOJ") is wasting no time in implementing the new cyber-security Executive Order (the EO), signed on February 28, 2024. As explained in our April 2024 blog post, the EO aims to portect Americans’...more
As we look back on the anti-corruption enforcement trends we saw in 2023, there were several key developments.
The Department of Justice (“DOJ”) brought 11 enforcement actions in 2023. Only six were against companies -...more
On February 22, 2023, the U.S. Department of Justice’s (DOJ) United States Attorneys’ Offices (USAO) announced a new Voluntary Self-Disclosure Policy that went into immediate effect. The purpose of the new policy is to create...more
As we look back on 2021, several anti-corruption enforcement trends emerge. The following summarizes the key developments of the prior year and trends to watch in 2022:
The Department of Justice (“DOJ”) brought 24...more
2/2/2022
/ Anti-Corruption ,
Biden Administration ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers
On June 3, 2021, President Biden issued a Memorandum on Establishing the Fight Against Corruption as a Core United States National Security Interest (the “Memo”). The Memo recognized the current Administration’s emphasis on...more
On April 29, 2021, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), the agency that enforces and administers U.S. economic and trade sanctions, announced a settlement with Dallas-based MoneyGram...more
The U.S. Department of Labor recently announced that the Occupational Safety and Health Administration (“OSHA”) will oversee worker retaliation complaints under the Criminal Antitrust Anti-Retaliation Act (“CAARA”) and the...more
On January 20, 2021, Joseph R. Biden, Jr. was inaugurated as the forty-sixth President of the United States. With the change in Presidential administration, we expect new priorities with regard to compliance and...more
As we look back on 2020, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2020:
•The Department of Justice (“DOJ”) brought 29 enforcement actions in 2020. 7 companies...more
On July 16, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of apparent violations of the North Korea Sanctions Regulations by Essentra FZE Company Limited...more
On June 1, 2020, the Department of Justice (DOJ) published an updated version of its guidance for “Evaluation of Corporate Compliance Programs,” originally published in February 2017. The guidance is intended to assist...more
In November 2019, the U.S. Department of Justice (“DOJ”) issued revisions to the Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (“Policy”). The Policy, which was first introduced in 2016, offers...more
The Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced on June 20, 2019 that Walmart, Inc. (“Walmart”) agreed to pay a combined total of $282.7 million to resolve the years-long...more
As discussed in Part 1 and Part 2 of this series, the seven core principles of an effective integrity compliance program apply to businesses of any size, but there is no one-size-fits-all model to compliance. What is...more
In our last alert, we discussed the first three fundamental categories of an effective compliance program: (1) Risk Assessment; (2) Management Buy-in; and (3) Code of Conduct [see our previous alert for the full discussion ...more
Never has the need for anti-corruption compliance programs for American companies been greater than it is today. This is not only for large multi-national companies, but for small to medium-sized businesses, particularly...more