Effective September 1, 2025, the UK’s Failure to Prevent Fraud offense will go into effect as part of the UK’s Economic Crime and Corporate Transparency Act 2023 (the ECCTA). The law significantly expands corporate liability...more
4/23/2025
/ Anti-Corruption ,
Compliance ,
Compliance Dates ,
Corporate Liability ,
Enforcement Priorities ,
EU ,
Failure to Prevent ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
New Legislation ,
Risk Management ,
UK
On February 5, 2025, Attorney General Pamela Bondi issued a memo requiring DOJ’s Foreign Corrupt Practice Act (“FCPA”) Unit to “prioritize investigations related to foreign bribery that facilitates the criminal operations of...more
3/25/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Cross-Border ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Joint Task Force ,
Serious Fraud Office (SFO) ,
Significant Transnational Criminal Organization ,
Switzerland ,
Trump Administration ,
UK
On January 20, President Trump issued an Executive Order designating certain international cartels as Foreign Terrorist Organizations (FTOs) or Specially Designated Global Terrorists (SDGTs). ...more
2/24/2025
/ Anti-Corruption ,
Bribery ,
Cartels ,
Compliance ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Risk Management ,
Significant Transnational Criminal Organization ,
Terrorist Organizations
The Fraud Section of the U.S. Department of Justice’s Criminal Division published its Year in Review last month, which showed an uptick for white collar enforcement in foreign corruption, financial and health care fraud. The...more
2/4/2025
/ Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Statistics ,
False Claims Act (FCA) ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Healthcare Fraud ,
Securities Fraud ,
Whistleblowers ,
White Collar Crimes
Latin America has been the focus of considerable attention by the DOJ. Despite strong ties based on trade, shared values and democratic traditions, Latin America is being tested with new and precarious challenges from...more
11/5/2024
/ Anti-Corruption ,
Biden Administration ,
Department of Justice (DOJ) ,
Enforcement ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Latin America ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Webinars ,
White Collar Crimes
Latin America has been the focus of considerable attention by the Biden Administration and the DOJ. Despite strong ties based on trade, shared values and democratic traditions, Latin America is being tested with new and...more
10/8/2024
/ Anti-Corruption ,
Biden Administration ,
Department of Justice (DOJ) ,
Enforcement ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Latin America ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Webinars ,
White Collar Crimes
Two recent court Foreign Corrupt Practices Act (FCPA) cases, a significant amendment to the Foreign Extortion Prevention Act (FEPA), and the new pilot whistleblower rewards program show that Anti-Corruption Enforcement...more
8/22/2024
/ Anti-Corruption ,
Bribery ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Federal Pilot Programs ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Government Investigations ,
Latin America ,
South Africa ,
Whistleblower Awards ,
Whistleblowers
The U.S. Department of Justice’s (“DOJ”) Criminal Division announced its new Corporate Whistleblower Awards Pilot Program on August 1, 2024. The Pilot Program incentivizes whistleblowers to provide information to the DOJ so...more
8/8/2024
/ CFTC ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On December 14, 2023, the United States House and Senate passed the National Defense Authorization Act (NDAA), which included the Foreign Extortion Prevention Act (FEPA). This bipartisan legislation, which Senator Sheldon...more
Two recent Foreign Corrupt Practices Act (FCPA) actions – a Department of Justice (DOJ) Opinion letter and an SEC settlement – underscore key diligence questions that legal and compliance departments should address when...more
9/11/2023
/ Civil Monetary Penalty ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Disgorgement ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Meal and Entertainment Expenditures ,
New Regulations ,
Opinion Letter ,
Pre-Judgment Interest ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Travel Expenses
The Department of Justice (DOJ) has been touting revisions to its corporate criminal enforcement policies and signaling increased action for nearly a year. Yesterday, Deputy Attorney General Lisa O. Monaco formally announced...more
9/19/2022
/ Compliance ,
Corporate Counsel ,
Corporate Culture ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Personal Liability ,
Voluntary Disclosure ,
White Collar Crimes
On March 3, 2022, at the 37th Annual American Bar Association Criminal Justice Section National Institute on White Collar Crime in San Francisco, Attorney General Merrick B. Garland emphasized that “the prosecution of...more
3/11/2022
/ Antitrust Violations ,
CARES Act ,
Centers for Medicare & Medicaid Services (CMS) ,
CFTC ,
Compliance ,
Corporate Misconduct ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Environmental Crimes ,
Foreign Corrupt Practices Act (FCPA) ,
IRS ,
Merrick Garland ,
Personal Liability ,
Securities Fraud ,
White Collar Crimes
Takeaways:
..In recent remarks, top DOJ officials stated that DOJ will “surge resources” and “redouble efforts” for corporate enforcement.
..Areas of particular concern include Foreign Corrupt Practices Act,...more
11/4/2021
/ Anti-Corruption ,
Benchmark Pricing ,
Biden Administration ,
Chief Compliance Officers ,
Compliance ,
Cooperation ,
Cybersecurity ,
Department of Justice (DOJ) ,
Energy Sector ,
Enforcement ,
Federal Contractors ,
Financial Fraud ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Government Investigations ,
Price Manipulation ,
White Collar Crimes
On June 3 of this year, the Biden Administration made plain its commitment to fighting corruption around the world, releasing a document identifying the fight against corruption “as an economic and national security priority”...more
8/25/2021
/ Anti-Corruption ,
Biden Administration ,
Blocked Person ,
Compliance ,
Corporate Transparency Act ,
Cross-Border Transactions ,
Enforcement ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Entities ,
Foreign Official ,
Internal Controls ,
Latin America ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Publicly-Traded Companies ,
SDN List ,
White Collar Crimes