On April 11, 2025, the U.S. Department of Justice’s National Security Division (NSD) issued a Compliance Guide to provide additional information to assist companies and individuals in complying with the NSD’s Data Security...more
On February 10, 2025, President Trump signed an executive order (EO) directing the Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days. During this period, Attorney...more
2/13/2025
/ Anti-Corruption ,
Attorney General ,
Competition ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Reform ,
Risk Management ,
Trump Administration
The Department of Justice ("DOJ") is wasting no time in implementing the new cyber-security Executive Order (the EO), signed on February 28, 2024. As explained in our April 2024 blog post, the EO aims to portect Americans’...more
Government officials underscored the importance of artificial intelligence (AI) enforcement and data protection during the American Bar Association’s 39th National Institute on White Collar Crime in March 2024. Specifically,...more
As we look back on the anti-corruption enforcement trends we saw in 2023, there were several key developments.
The Department of Justice (“DOJ”) brought 11 enforcement actions in 2023. Only six were against companies -...more
On September 28, 2023, the Securities and Exchange Commission (“SEC”) announced that it reached a settlement with Exelon Corporation and its subsidiary, Commonwealth Edison Company (“ComEd”), relating to charges that ComEd...more
On February 22, 2023, the U.S. Department of Justice’s (DOJ) United States Attorneys’ Offices (USAO) announced a new Voluntary Self-Disclosure Policy that went into immediate effect. The purpose of the new policy is to create...more
The following summarizes our team’s monitoring of key developments in anti-corruption enforcement during 2022 and what that may mean going forward in this new year:.....more
In late January 2022, the Department of Justice (“DOJ”) issued Opinion Procedure Release 22-01, its first Foreign Corrupt Practices Act (“FCPA”) Opinion since 2020. The opinion states that based on the specific facts...more
As we look back on 2021, several anti-corruption enforcement trends emerge. The following summarizes the key developments of the prior year and trends to watch in 2022:
The Department of Justice (“DOJ”) brought 24...more
2/2/2022
/ Anti-Corruption ,
Biden Administration ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers
On June 25, 2021, the Department of Justice (“DOJ”) and the Securities Exchange Commission (“SEC”) simultaneously announced that the international engineering and project management firm, Amec Foster Wheeler (“Foster Wheeler”...more
On June 3, 2021, President Biden issued a Memorandum on Establishing the Fight Against Corruption as a Core United States National Security Interest (the “Memo”). The Memo recognized the current Administration’s emphasis on...more
The Commodity Futures Trading Commission (“CFTC”) recently announced the settlement of its first enforcement action involving foreign corruption. In December 2020, the CFTC issued a Consent Order, finding that Houston-based...more
4/1/2021
/ Bribery ,
CFTC ,
Civil Monetary Penalty ,
Consent Order ,
Corruption ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Insider Trading ,
Kickbacks ,
Oil & Gas ,
Willful Misconduct
On January 20, 2021, Joseph R. Biden, Jr. was inaugurated as the forty-sixth President of the United States. With the change in Presidential administration, we expect new priorities with regard to compliance and...more
As we look back on 2020, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2020:
•The Department of Justice (“DOJ”) brought 29 enforcement actions in 2020. 7 companies...more
On October 22, 2020, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced the coordinated $2.9 billion resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action against The...more
On July 16, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of apparent violations of the North Korea Sanctions Regulations by Essentra FZE Company Limited...more
On June 1, 2020, the Department of Justice (DOJ) published an updated version of its guidance for “Evaluation of Corporate Compliance Programs,” originally published in February 2017. The guidance is intended to assist...more
In November 2019, the U.S. Department of Justice (“DOJ”) issued revisions to the Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (“Policy”). The Policy, which was first introduced in 2016, offers...more
As we look back on 2019, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2019:
The Department of Justice (“DOJ”) brought 29 enforcement actions in 2019. 12 guilty...more
On November 8, 2019 former Alstom S.A. senior executive Lawrence Hoskins was convicted on six counts of violating the Foreign Corrupt Practices Act (“FCPA”), three counts of money laundering, and two counts of conspiracy for...more
With the first half of 2019 in the rearview mirror, it is a good opportunity to review the overall trends in Foreign Corrupt Practices Act (“FCPA”) enforcement actions brought by the Department of Justice (“DOJ”) and...more
The Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced on June 20, 2019 that Walmart, Inc. (“Walmart”) agreed to pay a combined total of $282.7 million to resolve the years-long...more
The Department of Justice (“DOJ”) recently announced that it is declining to prosecute Cognizant Technology Solutions Corporation (“Cognizant”) for paying bribes to government officials in India in violation of the Foreign...more
As we kick off a new year, businesses should take the time to review their anti-corruption and compliance programs and make sure they are up-to-date and adaptable to the continuously changing environment. Here are five...more