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Anti-Corruption Criminal Investigations

Skadden, Arps, Slate, Meagher & Flom LLP

Khouri: Is UK-US Extradition on Its Way to Becoming an Ex-Tradition?

On 12 February 2025, the UK Supreme Court handed down its decision in El-Khouri v Government of the United States of America (El-Khouri), declining to extradite Joseph El-Khouri to the US. The ruling marks a pivotal moment in...more

Womble Bond Dickinson

Compliance Still Matters: The Future of FCPA Enforcement

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On January 20, President Trump issued an Executive Order designating certain international cartels as Foreign Terrorist Organizations (FTOs) or Specially Designated Global Terrorists (SDGTs). ...more

Troutman Pepper Locke

Key Considerations After DOJ Announces Shifting Enforcement Priorities

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On February 5, U.S. Attorney General (AG) Pam Bondi issued 14 memoranda to Department of Justice (DOJ) employees framing the DOJ's current policies and enforcement priorities. These shifting enforcement priorities are aligned...more

Latham & Watkins LLP

UK and European Considerations: President Trump Pauses FCPA Enforcement

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The executive order halts new and existing foreign bribery investigations — but enforcement risk in the UK and Europe remains. On February 10, 2025, President Trump issued an executive order titled “Pausing Foreign...more

DLA Piper

How Argentina Reached a Turning Point for Corporate Accountability and Compliance in 2024

DLA Piper on

In 2024, Argentina experienced a pivotal moment in corporate law enforcement with the first significant application of its Corporate Criminal Liability Law No. 27,401, enacted in 2018. This law holds private entities...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger

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Recorded at our 2024 White-Collar Symposium held in Philadelphia last month, this special episode dives into the landscape of white-collar criminal prosecution from the perspectives of Bill Baroni and Jesse Eisinger. Both...more

Mayer Brown

DOJ’s Criminal Division Updates Policy on 3 Key Topics: Artificial Intelligence, Whistleblower Programs, and Compliance Program...

Mayer Brown on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri (PDAAG), speaking at the Society of Corporate Compliance and Ethics Annual Compliance & Ethics Institute, announced three key updates to...more

The Volkov Law Group

Tracking FCPA Individual Enforcement

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While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more

Thomas Fox - Compliance Evangelist

The Foreign Corrupt Practices Handbook: Interview with the Authors

I recently spoke with the Foreign Corrupt Practices Act (FCPA) Handbook authors Robert Tarun and Peter Tomczak from Baker McKenzie for a two-part podcast episode. The depth of knowledge and experience in white-collar crime,...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the...

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In a single decade, the prosecutions of those accused of white-collar crime underwent a radical transformation. This thought-provoking episode will take you back in time to explore the DOJ's approach in the early 2000s Enron...more

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 3-the Discounted Fine

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more

The Volkov Law Group

Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm

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DOJ has promised an aggressive criminal corporate enforcement program against sanctions violators. The storm is coming and will arrive soon with a bang. There is no question that DOJ's enforcement initiative is coming -- it...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 2, the Need for Speed

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Jones Day

SDNY Launches Whistleblower Pilot Program to Encourage Self-Disclosure of Criminal Conduct

Jones Day on

The recently created SDNY Whistleblower Pilot Program encourages individuals to self-disclose certain criminal conduct and cooperate in resulting investigations and prosecutions. ...more

Morrison & Foerster LLP

MoFo's 2023 FCPA Year in Review

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, our Foreign Corrupt Practices Act (FCPA) Year In Review provides quick, visual representations of key trends in FCPA enforcement over...more

Ballard Spahr LLP

DOJ Bolsters International Cooperation to Combat Corruption

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Summary - The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...more

The Volkov Law Group

DOJ Repeats Warnings on Aggressive Criminal Enforcement of Sanctions and Export Controls

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As everyone knows, I tend to repeat myself — DOJ does as well.  Over the past year, DOJ has warned global companies — over and over — about the coming criminal enforcement storm against companies for sanctions and export...more

The Volkov Law Group

DOJ’s Enforcement and Compliance Changes: Weighing the Pros and Cons of Voluntary Disclosures

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The Justice Department certainly has altered the landscape of enforcement, compliance priorities, and ultimately corporate decisions surrounding voluntary disclosure.  It has become a little bit more complicated to sort out...more

The Volkov Law Group

DOJ Outlines Aggressive White Collar Enforcement Measures and New Compliance Expectations (Part I of II)

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The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement.  Last week, Lisa Monaco, DOJ’s...more

The Volkov Law Group

Ericsson Settles Breach of 2019 FCPA Deferred Prosecution Agreement: Agrees to Plead Guilty, Pay $206 Million, and Extend...

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Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty.  In 2019, Ericsson entered...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for January 2023

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Foley Hoag LLP

CEP Revisions Incentivize “Extraordinary” Corporate Cooperation

Foley Hoag LLP on

Earlier in January 2023, the U.S. Department of Justice (DOJ) announced revisions to its Corporate Enforcement Policy (CEP) under the Foreign Corrupt Practices Act (FCPA) for the first time since 2017. In his speech...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for September 2022

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and case developments from the past month,...more

The Volkov Law Group

DOJ Puts its New Stamp on FCPA Settlements: Unraveling the Glencore FCPA Settlement (Part II of V)

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The Justice Department has been promising a new, more aggressive approach to FCPA enforcement.  DOJ officials have made statements to that effect on numerous occasions.  The Biden Administration touted its elevation of the...more

The Volkov Law Group

You Win Some and You Lose Some:  DOJ’s Stumbles and Mixed Bag of Criminal Trial Results (Part I of III)

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Federal prosecutors know that their job – to represent the United States – is the highlight of their legal career. Speaking from experience, federal prosecutors are a privileged lot – they can announce in court they represent...more

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