On May 12, 2025, Assistant Attorney General Matthew R. Galeotti, head of the U.S. Department of Justice’s Criminal Division, issued a new policy memorandum entitled “Focus, Fairness, and Efficiency in the Fight Against...more
The landscape of criminal prosecution of foreign bribery has shifted, and the second Trump administration has made its priorities clear; however, companies still have 950 million reasons and counting to strengthen their...more
3/3/2025
/ Bribery ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
False Claims Act (FCA) ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Raytheon ,
Securities and Exchange Commission (SEC) ,
Whistleblowers
On February 10, 2025, President Trump issued an Executive Order entitled Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security. The executive order comes just days after the...more
While the balance of security, privacy, and public safety has always been a concern, recent cyberattacks have highlighted conflicting guidance by United States government officials, creating potential pitfalls for businesses....more
1/8/2025
/ CFTC ,
Compliance ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Data Breach ,
Data Preservation ,
Data Privacy ,
Data Security ,
Department of Justice (DOJ) ,
Encryption ,
Enforcement ,
FBI ,
Federal Trade Commission (FTC) ,
Hackers ,
Securities and Exchange Commission (SEC) ,
Telecommunications
Entities should continue preparing to comply with BOI reporting requirements.
On December 10, 2024, the Financial Crimes Enforcement Network (FinCEN) alerted businesses that, for now, they do not need to report their...more
12/13/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Constitutional Challenges ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
FinCEN ,
Popular ,
Preliminary Injunctions ,
Reporting Requirements ,
U.S. Treasury
In 2023, the number of federal corporate prosecutions remained far below the 25-year average after two consecutive years of increases.
..The DOJ’s Fraud Section secured just $690 million in penalties across eight...more
8/20/2024
/ Bribery ,
College Athletes ,
Colleges ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Due Diligence ,
Embezzlement ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Insider Trading ,
Name and Likeness ,
NCAA ,
Public Corruption ,
Regulatory Oversight ,
Safe Harbors ,
Sanctions ,
Title IX ,
Universities ,
Whistleblowers ,
White Collar Crimes
In 2022, the United States Department of Justice (“DOJ”) announced its decision to shut down the “China Initiative”—the controversial program used to investigate and prosecute academics, health care workers, and...more
5/23/2024
/ China ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Educational Institutions ,
Failure To Disclose ,
False Claims Act (FCA) ,
Grants ,
Indictments ,
Medical Research ,
National Institute of Health (NIH) ,
Physicians ,
Scientific Research ,
Settlement ,
Trump Administration
Since at least the adoption of the organizational Federal Sentencing Guidelines in 1991, the government has encouraged companies to adopt an effective compliance program that prevents and deters misconduct....more
5/21/2024
/ Acquisitions ,
Antitrust Violations ,
Chief Compliance Officers ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Due Diligence ,
Federal Rules of Criminal Procedure ,
Mergers ,
Safe Harbors ,
Successor Liability
We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group.
Each issue...more
4/3/2024
/ Anti-Corruption ,
Biden Administration ,
Bribery ,
Compliance ,
Corporate Misconduct ,
Corporate Transparency Act ,
Corruption ,
Criminal Convictions ,
Criminal Penalties ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Imprisonment ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Regulatory Standards ,
Securities Fraud ,
Sentencing ,
Title IX ,
Voluntary Disclosure ,
Wall Street ,
Whistleblower Awards ,
White Collar Crimes
We may be embarking on the end of the infamous transfer portal hold that restricts college-athletes from immediate competition after switching schools. In an age of increasing athlete autonomy, this ruling could impose a...more
On December 22, 2023, President Biden completed the proverbial “sandwich” against international bribery schemes by signing the groundbreaking Foreign Extortion Prevention Act (“FEPA”) into law....more