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DOJ’s Revised Policy on Crediting Fines: Emphasis on Victims

Without fanfare, the Department of Justice (DOJ or the Department) has published a memorandum revising its policy on when – and how – it will give credit to companies for fines and other payments made to other agencies,...more

DOJ’s New FCPA Guidelines: The Next Chapter in US Foreign Corruption Enforcement

The Department of Justice (DOJ) has released long-awaited guidance (FCPA Guidelines) regarding its approach to enforcement of the Foreign Corrupt Practices Act (FCPA) following the Executive Order (EO) pausing FCPA...more

Long-Awaited DOJ Guidance on White Collar Enforcement Priorities and Policies: Key Takeaways

This guidance follows a number of Executive Orders (EOs) and other memoranda from the DOJ, including (1) the February 10, 2025 EO pausing enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days, pending the...more

The Second Trump Administration’s First 100 days

The first 100 days of the second Trump Administration have been marked by a flurry of Executive Orders (EOs) and policy memoranda intended to advance President Donald Trump’s “America First” agenda. In the process, these...more

How FCPA and FCA Enforcement Could Change Under President Trump

To date, President Donald Trump has signed close to 100 Executive Orders (EOs) that signal the Trump Administration’s policies and key priorities, including objectives related to corporate crime and international trade and...more

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