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DOJ corporate enforcement overhaul: More declinations, fewer monitors, and FCPA enforcement still in question

On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to key corporate criminal enforcement policies. The revisions’ stated aim is to provide more clarity and certainty of outcome to companies that...more

DOJ's pause on FCPA is a compliance shake up for businesses

This article was originally published by Bloomberg Law on April 10, 2025, and is republished here with permission. Read the original article here: DOJ’s Pause on FCPA Is a Compliance Shake-Up for Businesses – Bloomberg...more

The new enforcement avengers? The UK, France, and Switzerland enforcement Taskforce: Local regulators join forces against global...

The United Kingdom (UK), France, and Switzerland announced on 20 March 2025 that they have jointly launched the International Anti-Corruption Prosecutorial Taskforce to combat complex international white-collar crime. The...more

Caught in the crosshairs: Mitigating supply chain risks from Cartel FTO designations

On February 20, the U.S. Department of State (State) designated eight cartels as Foreign Terrorist Organizations (FTOs). These designations are the latest development in the Trump administration’s realignment of the U.S....more

Criminal FCPA enforcement paused. Now what?

On February 10, 2025, President Trump ordered the U.S. Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) and issue new enforcement guidelines that take into consideration U.S....more

Past is Prologue? DOJ Enforcement under POTUS 47

On 21 November 2024, hot off a political comeback for the history books, president-elect Donald Trump announced former Florida attorney general Pam Bondi as his nominee for Attorney General. The announcement followed the...more

The Foreign Extortion Prevention Act (FEPA) signed into law: What it means for companies worldwide

On December 22, 2023, President Biden signed the Foreign Extortion Prevention Act (FEPA) into law, revising Section 201 of Title 18 of the U.S. Code concerning bribery of government officials. This significant development...more

Key takeaways from the 40th ACI International Conference on the FCPA

Last week at the 40th American Conference Institute (ACI) International Conference on the FCPA, government enforcement agencies such as the Department of Justice (DOJ), Securities and Exchange Commission (SEC), and UK Serious...more

No monkey business – Recent FCPA probe into wildlife trafficking in Asia

An Indiana-based contract research organization for pharmaceutical testing is being investigated by the Securities and Exchange Commission (SEC) for potential violations of the Foreign Corrupt Practices Act (FCPA). The...more

DOJ issues rare FCPA advisory opinion regarding the extortion exception

On January 21, 2022, the Department of Justice (“DOJ”) issued a Foreign Corrupt Practices Act (“FCPA”) Opinion Procedure Release (the “OPR” or “OPR 22-01”) addressing the rarely discussed extortion exception to the FCPA’s...more

OECD releases latest Anti-Corruption recommendations—most significant Anti-Bribery update since 2009

On November 25th, the OECD Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions adopted a series of recommendations for member countries to implement, in an effort to curb...more

2021 Enforcement Horizon: New administration civil and criminal enforcement efforts

With a new administration comes new policies and enforcement priorities. Today, as we kickoff our new series “2021 Enforcement Horizon,” we take notice of what has already been a very active administration, and we consider...more

Doing business in the United States

The U.S. is one of the easiest jurisdictions in the world in which to do business1 . 1 Regulatory barriers are generally low, establishing a branch or business entity is quick and easy, labor and employment laws are much...more

Individual prosecutions under the FCPA – more trials and more caselaw

This month’s analysis looks at individual prosecutions under the Foreign Corrupt Practices Act (FCPA). Prosecutions have markedly increased over the last five years, and this will better define local, regional, and...more

DOJ refines cooperation requirements of FCPA corporate enforcement policy

On November 20, 2019, the U.S. Department of Justice (DOJ) announced several subtle, but important, adjustments to its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. These recent changes relate to...more

U.S. and Brazilian Authorities Reportedly Cooperating in Investigation of Alleged Bribery and Price Fixing Related to Medical...

In a May 17, 2019 press report that has been widely distributed in Brazil and the United States, Brazilian Federal Prosecutor Marisa Ferrari confirmed that the U.S. Federal Bureau of Investigation (FBI), the U.S. Department...more

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