On June 9, 2025, the Department of Justice (DOJ) issued new guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (FCPA), following a four-month pause of new FCPA investigations per President...more
When an executive learns that she is being investigated for fraud, her first reaction often is: “But I didn’t intend for anyone to lose money!” This entirely understandable response may well be true (and lead the executive to...more
As we discussed in this April 7 blog post, the US Department of Justice (DOJ) can pursue civil penalties for tariff evasion under the False Claims Act (FCA), including against companies that are aware of tariff evasion by...more
The Department of Justice continues to make clear that one of its principal corporate enforcement priorities is encouraging companies to voluntarily self-disclose misconduct. To that end, the DOJ recently announced its...more
On February 22, 2023, the US Department of Justice announced a new voluntary self-disclosure policy for corporate criminal enforcement in US attorney’s offices nationwide. The policy offers concrete and meaningful incentives...more