On August 21, 2025, Acting Assistant Attorney General Matthew R. Galeotti delivered remarks at the American Innovation Project (AIP) Summit in Jackson, Wyoming. Mr. Galeotti’s remarks focused on the digital asset ecosystem...more
The U.S. Department of Justice (“DOJ”) Criminal Division and the U.S. Attorney’s Office for the Western District of North Carolina recently announced the first non-prosecution agreement (“NPA”) coming out of DOJ’s Health Care...more
8/26/2025
/ Artificial Intelligence ,
Centers for Medicare & Medicaid Services (CMS) ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Fraud ,
Healthcare Fraud ,
Medicare Advantage ,
Non-Prosecution Agreements ,
Self-Disclosure Requirements ,
Voluntary Disclosure
Seven months into President Donald Trump’s second administration, a new trade paradigm is emerging that presents challenges for everyone involved in bringing products into the United States. ...more
8/18/2025
/ Court of International Trade ,
Criminal Prosecution ,
Customs ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
False Claims Act (FCA) ,
Importers ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Jurisdiction ,
Tariffs ,
Trump Administration ,
US Trade Policies ,
Whistleblowers
Over the past week, the U.S. Department of Justice (“DOJ”) unsealed its first Foreign Corrupt Practices Act (“FCPA”) enforcement action and issued its first declination since the pause in FCPA enforcement mandated by...more
8/18/2025
/ Anti-Corruption ,
Bribery ,
Corporate Counsel ,
Declination ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
FCPA Corporate Enforcement Policy (CEP) ,
Foreign Corrupt Practices Act (FCPA) ,
Mexico ,
Self-Disclosure Requirements ,
Significant Transnational Criminal Organization ,
Trump Administration ,
Voluntary Disclosure
On July 2, 2025, the U.S. Court of Appeals for the Second Circuit ruled in United States v. Lopez that foreign commercial bribery schemes fall within the ambit of the honest services wire fraud statute, 18 U.S.C. §...more
7/11/2025
/ Appeals ,
Bribery ,
Conspiracies ,
Corruption ,
Criminal Conspiracy ,
Criminal Convictions ,
Criminal Prosecution ,
Enforcement Actions ,
Fédération Internationale de Football Association (FIFA) ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Jurisdiction ,
SCOTUS ,
Soccer ,
White Collar Crimes ,
Wire Fraud ,
World Cup
On June 5, 2025, the Department of Justice (“DOJ”) directed prosecutors to prioritize compensating victims when resolving multiagency investigations involving corporate defendants. ...more
6/13/2025
/ Corporate Crimes ,
Crime Victims ,
Declination ,
Department of Justice (DOJ) ,
Government Investigations ,
Investigations ,
Non-Prosecution Agreements ,
Parallel Proceedings ,
Penalties ,
Policy Memorandums ,
Restitution ,
Settlement ,
Voluntary Disclosure ,
White Collar Crimes
On June 10, 2025, the Deputy Attorney General issued the highly anticipated Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) (“Guidelines”), complying with the directive in President...more
6/11/2025
/ Bribery ,
Cartels ,
Compliance ,
Corporate Counsel ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
New Guidance ,
Terrorist Organizations ,
Trump Administration
On May 12, 2025, Matthew Galeotti, the Head of the Criminal Division at the Department of Justice ("DOJ") issued a new white collar enforcement plan (“Enforcement Plan”) titled “Focus, Fairness, and Efficiency in the Fight...more
5/14/2025
/ Bribery ,
Compliance ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
Since the beginning of his second term, President Donald Trump has implemented policy changes in accordance with top administration priorities that are likely to significantly alter the enforcement landscape for non-U.S....more
Anti-bribery and corruption agencies in the UK, France and Switzerland today announced a shared commitment to tackling international bribery and corruption, by way of a new taskforce intended to strengthen collaboration....more
3/21/2025
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Compliance ,
Corruption ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
Enforcement Authority ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
International Trade ,
Penalties ,
Switzerland ,
UK ,
White Collar Crimes
Soon after being sworn in, President Trump issued Executive Orders identifying top administration priorities: combating illegal immigration, drug cartels, and unlawful DEI practices. Taking a similar tack, on her first day in...more
Foreign Corrupt Practices Act (FCPA) enforcement activity increased overall in 2024, with a notable uptick in Department of Justice (DOJ) enforcement actions compared to 2023, despite a decrease in public Securities and...more
1/31/2025
/ Anti-Corruption ,
Compliance ,
Corporate Counsel ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Penalties ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
White Collar Crimes
The U.S. Department of Justice (DOJ) recently updated the Evaluation of Corporate Compliance Programs (ECCP), which prosecutors use to assess the effectiveness of a corporation’s compliance program, in large part to address...more
10/8/2024
/ Anti-Retaliation Provisions ,
Artificial Intelligence ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Emerging Technologies ,
Risk Assessment ,
Risk Management ,
Risk Mitigation ,
Whistleblower Protection Policies ,
Whistleblowers
On August 1, 2024, the Department of Justice officially launched a three-year pilot program to reward whistleblowers who report corporate misconduct....more
8/7/2024
/ CFTC ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
FinCEN ,
Forfeiture ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On April 15, 2024, the Criminal Division of the Department of Justice (DOJ) announced the Pilot Program on Voluntary Self-Disclosure for Individuals, providing transparency regarding the circumstances in which Criminal...more
While the 2022 M&A market was buoyed by deal carryover from 2021 and more conducive market conditions in the first half of the year, the 2023 M&A market felt the impact of the Federal Reserve’s most aggressive interest rate...more
3/22/2024
/ Acquisitions ,
Antitrust Provisions ,
Capital Markets ,
Competition ,
Department of Justice (DOJ) ,
Financial Markets ,
Initial Public Offering (IPO) ,
Mergers ,
Safe Harbors ,
Securities and Exchange Commission (SEC) ,
Takeovers ,
Venture Capital
On March 7, 2024, Deputy Attorney General Lisa Monaco announced Department of Justice (DOJ) initiatives to incentivize whistleblowers with payouts from civil or criminal forfeitures and to integrate artificial intelligence...more
3/12/2024
/ Artificial Intelligence ,
CFTC ,
Corporate Crimes ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more
1/31/2024
/ Acquisitions ,
Anti-Bribery ,
Anti-Corruption ,
Clawbacks ,
Compliance ,
Cooperation ,
Data Protection ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Enforcement Guidance ,
Enforcement Priorities ,
Enforcement Statistics ,
Executive Compensation ,
FCPA Corporate Enforcement Policy (CEP) ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Latin America ,
Mergers ,
Pilot Programs ,
Safe Harbors ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Voluntary Disclosure
On December 14, 2023, the U.S. Congress (Congress) passed the Foreign Extortion Prevention Act (FEPA), as a part of the Fiscal Year 2024 National Defense Authorization Act. The FEPA, which received bipartisan support, makes...more
On October 4, 2023, Deputy Attorney General Lisa Monaco announced a new safe harbor policy that may shield companies from criminal prosecution for misconduct they uncover at companies they are acquiring or have recently...more
10/6/2023
/ Acquisitions ,
Antitrust Division ,
Cooperation ,
Corporate Misconduct ,
Criminal Liability ,
De-Risking ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Guidance ,
Mergers ,
Safe Harbors ,
Self-Reporting
On March 3, 2023, as part of the rollout of several updates to its guidance on corporate compliance programs, the Department of Justice (DOJ) released a new policy aimed at incentivizing compliance-driven compensation and...more
3/6/2023
/ Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
New Guidance ,
Risk Assessment ,
White Collar Crimes
On February 22, 2023, the Department of Justice (DOJ) issued a Voluntary Self-Disclosure Policy (VSDP) which, effective immediately, applies to all U.S. Attorneys’ Offices (USAOs) nationwide with respect to corporate criminal...more
While Foreign Corrupt Practices Act (FCPA) enforcement activity has not come close to returning to the heights seen a few years ago, 2022 reflected significant increases from the prior year in both the number of cases against...more
2/10/2023
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
CFTC ,
Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Criminal Fines ,
Corruption ,
Cross-Border ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
In June 2022, the US Supreme Court issued a landmark decision in Dobbs v. Jackson Women’s Health Organization, reversing Roe v. Wade and holding that the US constitution no longer includes a right to abortion. The Court’s...more
Assistant Attorney General Kenneth A. Polite, Jr. Announces Changes to Department of Justice Criminal Division’s Corporate Enforcement Policy -
On January 17, 2023, Assistant Attorney General for the Criminal Division...more
1/19/2023
/ Compliance ,
Compliance Management Systems ,
Compliance Monitoring ,
Cooperation ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Voluntary Disclosure ,
White Collar Crimes