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Cadwalader, Wickersham & Taft LLP

The Pause is Over—the FCPA Lives On

On June 9, 2025, the U.S. Department of Justice (DOJ) announced the resumption of Foreign Corrupt Practices Act (FCPA) enforcement, ending the enforcement pause initiated by Executive Order 14209. In doing so, Deputy Attorney...more

The Volkov Law Group

Supreme Court’s Wire Fraud Decision Raises Risks for Government Contractors

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In a unanimous decision, the U.S. Supreme Court, in Kousisis v. United States affirmed a lower court’s decision upholding a conviction of federal wire fraud for inducing a victim to enter into a transaction under materially...more

Mayer Brown

FCPA Un-Paused: DOJ Announces New Guidelines for FCPA Enforcement

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On June 9, 2025, in a memorandum entitled Guidelines for Investigations and Enforcement of the FCPA(the “Guidelines”), the Department of Justice (DOJ) signaled that Foreign Corrupt Practices Act (FCPA) investigations and...more

Venable LLP

FCPA Enforcement Resumes with New Guidelines Focused on Strategic U.S. Interests

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The pause on enforcement of the Foreign Corrupt Practices Act (FCPA) is over. On June 9, the Deputy Attorney General of the Department of Justice (DOJ) issued a memorandum (the June 9 Memorandum) establishing new enforcement...more

Benesch

New FCPA Guidance Underscores Importance of Internal Compliance for Companies Doing Business Abroad

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On June 9, 2025, Todd Blanche, Deputy Attorney General for the United States Department of Justice, published guidelines for investigations and prosecutions under the Foreign Corrupt Practices Act (FCPA). These guidelines...more

Bass, Berry & Sims PLC

Is the “Pause” Over? DOJ Resumes FCPA Enforcement, Announces Guidelines

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On June 9, Deputy Attorney General Todd Blanche issued a memorandum entitled Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (the Memo) addressed to the head of the Criminal Division of the...more

Sheppard Mullin Richter & Hampton LLP

DOJ Releases Promised Guidelines for Investigation and Enforcement Under the FCPA

On Monday June 9, 2025, the Deputy Attorney General Todd Blanche released “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act.” This much anticipated update directly responds to Executive Order...more

Bradley Arant Boult Cummings LLP

Justice Rushed Is Justice Denied: Why Alabama’s Attorney General Can Show Wisdom Rather Than Power on Hemp

One of my favorite quotes from Justice Potter Stewart (naturally, a Supreme Court justice writing about watching pornography is my favorite) is “[f]airness is what justice really is.” The Alabama attorney general has an...more

Cozen O'Connor

Pennsylvania Perspective for Thursday, June 12, 2025

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Gov. Shapiro, Amazon Unveil Historic $20B AI Investment in PA - On Monday, Governor Josh Shapiro (D) and Amazon announced a $20 billion investment to build AI infrastructure in Pennsylvania, including two major data centers...more

Cozen O'Connor

Connecticut Law Aims to Weed Out Illegal Sales of Cannabis and Tobacco Products

Cozen O'Connor on

Connecticut AG William Tong has announced the passage of House Bill No. 7181, which will provide new civil and criminal tools and incentives to state regulators and law enforcement to pursue actions against illegal cannabis...more

Cozen O'Connor

Democratic AGs Take Aim at ATF’s Decision to Distribute Firearm Triggers

Cozen O'Connor on

A group of 16 Democratic AGs filed a lawsuit in federal court challenging the decision by the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) to redistribute thousands of Forced Reset Triggers (FRTs) throughout the...more

BakerHostetler

FCPA Enforcement Is Back with a New Enhanced Focus on Protecting US Business Abroad, National Security, Individuals and (of...

BakerHostetler on

U.S. Department of Justice (DOJ) Deputy Attorney General Todd Blanche issued a memorandum on June 9 (the Memo), announcing DOJ will resume enforcement of the Foreign Corrupt Practices Act (FCPA) after its brief hiatus....more

Hogan Lovells

FCPA reloaded: The DOJ “unpauses” enforcement – But is it a new level?

Hogan Lovells on

On June 9, 2025, Deputy Attorney General Todd Blanche issued revised enforcement guidelines for the Foreign Corrupt Practices Act (FCPA), officially ending the FCPA enforcement pause that Executive Order 14209 (EO) instituted...more

Husch Blackwell LLP

DOJ Poised to Reboot FCPA Investigations and Enforcement

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Issued on February 10, 2025, Executive Order 14209 (“Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security”) called on the Department of Justice (DOJ) to “review guidelines and...more

Paul Hastings LLP

New DOJ FCPA Guidelines Target Cases Linked to US Strategic Interests

Paul Hastings LLP on

On June 9, U.S. Deputy Attorney General Todd Blanche issued a memorandum entitled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA),” which establishes guidelines to ensure that FCPA...more

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

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