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ArentFox Schiff

FCA Enforcement & Compliance Digest — Summer 2025 False Claims Act Newsletter

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Welcome to the Summer 2025 issue of “FCA Enforcement & Compliance Digest,” our quarterly newsletter in which we compile essential updates on False Claims Act (FCA) enforcement trends, litigation, agency guidance, and...more

King & Spalding

A New Era of FCPA Enforcement

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On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the “Blanche Memorandum”) detailing new guidelines for the Department of Justice’s approach to investigating and enforcing the Foreign Corrupt...more

Wilson Sonsini Goodrich & Rosati

DOJ to Use FCPA as a Tool for Advancing White House Priorities and American Competitiveness

In February 2025, President Trump signed an executive order directing the U.S. Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) and to update its guidelines for enforcing the FCPA....more

Morris, Manning & Martin, LLP

The Department of Justice's Criminal Division is Now Prioritizing Enforcement Related to Trade, Tariff, and Customs Fraud:...

On May 12, 2025, the U.S. Department of Justice’s (DOJ) Criminal Division released a memorandum containing the Trump Administration’s new white collar enforcement priorities. Consistent with the Administration’s heightened...more

Baker Donelson

Trade Enforcement Risks Escalate with Increasing Tariffs: What Companies Should Do to Mitigate Risk

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The increase in tariffs and export control actions by the Trump Administration has led to additional reporting and compliance obligations for companies that import and export goods. To ensure these new tariffs and rules are...more

A&O Shearman

New UK SFO guidance on corporate cooperation and enforcement

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With much fanfare, the Serious Fraud Office has launched its refreshed guidance on Corporate Cooperation and Enforcement. The guidance coincides with several new powers the SFO is eager to use. Overall, the agency is...more

White & Case LLP

DOJ Issues Promised FCPA Guidance: Decoding the Message

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On June 10, 2025, the Department of Justice (“DOJ”) issued a memorandum establishing guidelines for enforcement of the Foreign Corrupt Practices Act (the “Guidelines” and “FCPA,” respectively). The DOJ issued the Guidelines...more

Perkins Coie

FCPA Is Here to Stay: DOJ Reaffirms Commitment to Enforce FCPA

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On June 9, 2025, the U.S. Department of Justice (DOJ) unveiled new guidelines for enforcing the Foreign Corrupt Practices Act (FCPA), marking a pivotal shift in how corruption cases are pursued. The guidelines seek to...more

McDermott Will & Emery

DOJ Revives FCPA Enforcement With Narrower Scope

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On February 10, 2025, President Donald Trump issued an executive order pausing new Foreign Corrupt Practices Act (FCPA) investigations for 180 days (the EO). The EO directs the US Department of Justice (DOJ) to review...more

Skadden, Arps, Slate, Meagher & Flom LLP

Deputy Attorney General Issues FCPA Guidelines Resuming Limited Enforcement

Key Points - - The U.S. Department of Justice (DOJ) will resume investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA), prioritizing, in part, FCPA actions involving cartels and transnational...more

Ballard Spahr LLP

Focused FCPA Enforcement: Emphasizing Security and Strategic Interests

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On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the DAG memorandum) updating the Department of Justice’s (DOJ) enforcement guidelines for the Foreign Corrupt Practices Act (FCPA) in accordance with...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Hits Play: The End of the FCPA “Pause” and Return to Enforcement

On June 9, 2025, the Deputy Attorney General issued a Memorandum detailing the administration’s new FCPA guidelines for all current and future investigations and enforcement actions. According to the Head of DOJ’s Criminal...more

Cozen O'Connor

Illinois Insights: An update from Cozen O'Connor (6/11)

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Illinois Senate President Don Harmon faces potential $9.8 million fine for improperly accepting campaign cash - “State election officials have informed Senate President Don Harmon that he will face more than $9.8 million in...more

Lowenstein Sandler LLP

The End of 180 Days of Uncertainty? DOJ Closes Current FCPA Investigations, Issues New Guidelines for FCPA Enforcement

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On June 9, Deputy Attorney General Todd Blanche issued a memorandum (the Memorandum) outlining revised guidelines for investigation and enforcement of the Foreign Corrupt Practices Act (FCPA). The U.S. Department of Justice...more

Cooley LLP

DOJ Announces Priorities and Policy Updates – Including Tariff Compliance Enforcement, Expansion of Whistleblower Program

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Over the last year, we have paid close attention to the increasingly complicated and evolving landscape companies are facing in light of changing government enforcement priorities, including the Department of Justice’s...more

Baker Botts L.L.P.

Back from the Dead? Takeaways from US DOJ’s New Guidelines for FCPA Investigations and Enforcement

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On June 9, 2025, the Deputy Attorney General of the United States Department of Justice issued “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (the “Memorandum”). The Memorandum...more

Ropes & Gray LLP

DOJ’s New FCPA Playbook: “Time To Get To Work”

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On June 9, 2025, the U.S. Department of Justice (“DOJ” or the “Department”) issued the highly anticipated guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (“FCPA”) (“FCPA Guidelines”),...more

Cozen O'Connor

DOJ Restarts Enforcement of Foreign Corrupt Practices Act, Focusing on U.S. Interests

Cozen O'Connor on

On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum titled "Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)." The memo follows a four-month review triggered by...more

Ankura

Unmasking the Dark Side of OnlyFans: Combating Human Trafficking and Sexual Exploitation with Effective Research Strategies

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1 1 24 1 While some users have referred to OnlyFans as empowering, unfortunately, the site also plays a role in human trafficking and exploitation. The U.S. Department of State estimates that, at any given time, there are an...more

ArentFox Schiff

DOJ Issues New Guidelines for FCPA Investigation and Enforcement

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On June 9, Deputy US Attorney General Todd Blanche issued a memorandum outlining new guidelines for the enforcement of the Foreign Corrupt Practices Act (FCPA)....more

DLA Piper

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

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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

Eversheds Sutherland (US) LLP

DOJ issues updated guidance focused on protecting US companies

On June 9, 2025, US Department of Justice (DOJ) Deputy Attorney General Todd Blanche issued “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (Guidelines), instructing prosecutors...more

Perkins Coie

European Response to DOJ’s Changes in FCPA Enforcement

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In recent months, the U.S. Department of Justice (DOJ) has hit “pause” on enforcement of the Foreign Corrupt Practices Act (FCPA) and reoriented its other enforcement priorities away from investigating and prosecuting...more

A&O Shearman

EU sanctions enforcement is on the rise

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A clear trend is emerging: Across the EU, authorities are intensifying the enforcement of EU sanctions, and it is anticipated that the prosecution of related criminal offenses will increase. As a result, the regulatory...more

Morgan Lewis

DOJ Issues Anticipated FCPA Enforcement Guidelines with Focus on US Interests, Individual Accountability

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The US Department of Justice has issued new guidance regarding enforcement of the Foreign Corrupt Practices Act (FCPA) in a June 9 memorandum from Deputy Attorney General Todd Blanche. The memorandum formalizes a shift in...more

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