The executive order halts new and existing foreign bribery investigations — but enforcement risk in the UK and Europe remains.
On February 10, 2025, President Trump issued an executive order titled “Pausing Foreign...more
2/14/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Misconduct ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
EU ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
UK
Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors.
In a speech at Georgetown University Law Center on...more
2/7/2023
/ Bribery ,
Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Corruption ,
Declination ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
Updated DOJ policies will continue to focus on individual accountability and corporate recidivism, while aiming to provide additional incentives for voluntary self-reporting, foster greater transparency on use of monitors,...more
9/28/2022
/ Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Corporate Officers ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Personal Liability ,
Voluntary Disclosure
The bill seeks to extend certain provisions of the Foreign Corrupt Practices Act.
The U.S. Congress continues to take interest in implementing legislation to curb alleged human rights abuses in the supply chain in China...more
UK companies should be aware of the increasing focus on corporate culture by regulators on both sides of the Atlantic.
In a recent speech that has garnered significant attention, US Deputy Attorney General Lisa Monaco...more
11/8/2021
/ Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Crimes ,
Corporate Culture ,
Department of Justice (DOJ) ,
Environmental Social & Governance (ESG) ,
Financial Conduct Authority (FCA) ,
Foreign Corrupt Practices Act (FCPA)
The priorities will impact non-US companies who may face a US DOJ with a renewed emphasis on combating corporate crime.
In a recent speech that has garnered significant attention, the Deputy Attorney General of the...more
11/5/2021
/ Biden Administration ,
Compliance ,
Compliance Monitoring ,
Corporate Crimes ,
Corporate Culture ,
Corporate Misconduct ,
Corporate Monitoring ,
Criminal Prosecution ,
Cross Border Privacy Rules (CBPR) ,
Cross-Border ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corporations ,
Foreign Corrupt Practices Act (FCPA) ,
Non-Prosecution Agreements ,
Personal Liability ,
UK ,
White Collar Crimes
Guidance sets out the SFO’s expectations for investigations but leaves open questions, particularly for cross-border investigations.
On 6 August 2019, the UK Serious Fraud Office (SFO) issued its much-anticipated Corporate...more
8/10/2019
/ Cooperation ,
Corporate Cooperation Credits ,
Corporate Investigations ,
Criminal Investigations ,
Cross-Border ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Privilege Waivers ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
UK ,
White Collar Crimes
Ruling holds that the government cannot use conspiracy and accomplice liability theories to reach foreign nationals that lack US ties.
Key Points:
..Non-resident foreign nationals who are not otherwise subject to direct...more
A new UK policy establishes a commitment to providing victims of overseas bribery with compensation; however, important questions remain that will impact implementation.
The UK’s Serious Fraud Office (SFO), the Crown...more
6/18/2018
/ Bribery ,
Costa Rica ,
Criminal Proceeds ,
Cross-Border ,
Financial Crimes ,
Foreign Corrupt Practices Act (FCPA) ,
Just Compensation ,
Proceeds of Crime Act 2002 (POCA) ,
Restitution ,
Serious Fraud Office (SFO) ,
UK
The revised FCPA Corporate Enforcement Policy signals DOJ’s emphasis on corporate voluntary self-disclosure, rewarding cooperating companies with a presumption in favor of declination and reductions in penalties.
...more
FCPA Opinion Release provides insight into the jurisdictional reach of the FCPA and the level of due diligence the DOJ expects.
On November 7, 2014, the US Department of Justice (DOJ) issued its second and final...more