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Bribery Foreign Corrupt Practices Act (FCPA) Enforcement Actions

Husch Blackwell LLP

State Attorneys General May Step Up Foreign Anti-Corruption Enforcement Efforts Following Federal Enforcement Pause

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For decades Foreign Corrupt Practices Act (FCPA) enforcement has been largely considered a federal matter, with the U.S. Department of Justice (DOJ) enforcing the statute’s criminal provisions.[1] Enacted in 1977, FCPA...more

King & Spalding

Anti-Bribery and Anti-Corruption Enforcement in the U.S., UK, and Europe post-FCPA Pause

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We have previously written about the impact of the pause in enforcement of the FCPA implemented by the Trump Administration on non-American companies.1 Although the 180-day review period the Executive Order provided to the...more

White & Case LLP

A Vested Interest in Honest Business: California Attorney General Reminds Businesses that FCPA Violations Remain Actionable under...

White & Case LLP on

On April 2, 2025, California Attorney General Rob Bonta issued a Legal Advisory reminding businesses operating in California that foreign bribery remains illegal under California law and that violations of the US Foreign...more

Morgan Lewis

Cartels, TCOs, ‘Instrumentalities of a Government’: Reassessing FCPA Risk Amid Shifting US Enforcement Priorities

Morgan Lewis on

Whether cartels do or do not qualify as “instrumentalities of a government” under current FCPA law or based on the AG’s forthcoming revised FCPA guidance, their entanglement with corrupt officials and influence over local...more

Wilson Sonsini Goodrich & Rosati

California AG Warns Companies That FCPA Violations Are Still Enforceable Notwithstanding Federal Pause

On April 2, 2025, California Attorney General Rob Bonta issued a press release and legal advisory reminding businesses operating in California that violations of the Foreign Corrupt Practices Act (FCPA) are still actionable...more

Mayer Brown

The Future of Anti-Corruption Enforcement: Potentially Increasing State and Non-US Prosecutions as an Alternative to the FCPA

Mayer Brown on

On February 10, 2025, President Donald Trump signed an executive order instructing the United States Department of Justice (“DOJ”) to pause enforcement of the Foreign Corrupt Practices Act (“FCPA”) for a period of 180 days....more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for March 2025

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

Dechert LLP

Eurostars Align to Tackle Corruption

Dechert LLP on

Formation of new anti-corruption alliance in Europe and what it means for international enforcement - On 20 March 2025, the UK Serious Fraud Office (SFO), French Parquet National Financier (PNF) and the Office of the...more

Baker Donelson

DOJ Dismisses FCPA Charges Against Former Cognizant Executives Following New Policy

Baker Donelson on

On April 2, 2025, the U.S. Department of Justice (DOJ) moved to dismiss the Foreign Corrupt Practices Act (FCPA) case against former Cognizant Technology Solutions Corp. executives Gordon Coburn and Steven Schwartz, United...more

ArentFox Schiff

California Attorney General Warns That FCPA Violations Are Actionable Under the State’s Unfair Competition Law

ArentFox Schiff on

On April 2, California Attorney General (AG) Rob Bonta issued an alert reminding businesses operating in California that it is illegal to violate the Foreign Corrupt Practices Act (FCPA)....more

Bracewell LLP

US Halt on Foreign Anti-Corruption Enforcement Prompts New European Taskforce

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Approximately two weeks ago, British, French and Swiss law enforcement authorities announced the creation of a new international alliance. With their joint Founding Statement (“Statement”), the three countries established the...more

Thomas Fox - Compliance Evangelist

10 For 10: Top Compliance Stories For The Week Ending April 5, 2025

Welcome to 10 For 10, the podcast that brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance, brings you the compliance professional and the compliance stories you need to...more

Hogan Lovells

The new enforcement avengers? The UK, France, and Switzerland enforcement Taskforce: Local regulators join forces against global...

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The United Kingdom (UK), France, and Switzerland announced on 20 March 2025 that they have jointly launched the International Anti-Corruption Prosecutorial Taskforce to combat complex international white-collar crime. The...more

Jones Day

The UK, France, and Switzerland Form New Anti-Corruption Enforcement Task Force

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On March 20, 2025, the UK's Serious Fraud Office ("SFO"), France's National Financial Prosecutor's Office ("PNF"), and the Office of the Attorney General of Switzerland ("OAG") announced the creation of a new task force to...more

Ankura

Internal Control Lessons Learned from Global Anti-Corruption Enforcement in 2024

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2024 saw another strong year of Foreign Corruption Practices Act (FCPA) enforcement actions from the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). There were 15 resolutions with...more

Jenner & Block

Client Alert: The Case for Compliance: Why UK and EU Businesses Should Continue to Invest in Their Compliance Programs

Jenner & Block on

On 20 March 2025, enforcement agencies from the UK, France and Switzerland affirmed their shared commitment to tackling international bribery and corruption and founded a new taskforce to strengthen collaboration. Director of...more

WilmerHale

UK, French, and Swiss Enforcement Authorities Announce New Alliance

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Anti-bribery and corruption agencies in the UK, France and Switzerland today announced a shared commitment to tackling international bribery and corruption, by way of a new taskforce intended to strengthen collaboration....more

Thomas Fox - Compliance Evangelist

Regulatory Ramblings: Episode 65 – The Trump Administration’s Decision to Halt FCPA Enforcement – The Implications for Asia and...

Three weeks after returning to the White House, US President Donald Trump signed an executive order on February 10 directing the Justice Department to pause prosecutions of Americans accused of bribing foreign government...more

Ankura

The Extended Network: Managing Third Parties' Bribery Risks

Ankura on

Approximately 90% of U.S. Foreign Corrupt Practices Act (FCPA) enforcement cases from its inception in 1978 have involved third-party intermediaries engaging in bribery schemes. The reduced level of control or oversight...more

Thomas Fox - Compliance Evangelist

10 For 10: Top Compliance Stories For the Week Ending March 15, 2025

Welcome to 10 For 10, the podcast that brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance, brings to you the compliance professional and the compliance stories you need...more

A&O Shearman

US Attorney For The District of New Jersey Reverses Course And Requests Adjournment For Foreign Bribery Case Against Tech...

A&O Shearman on

On March 4, 2025, one day before a trial against former tech executives for alleged foreign bribery charges was set to commence, the United States Attorney for the District of New Jersey requested 180-day adjournment. The...more

Lathrop GPM

Trump Executive Order Pausing FCPA Enforcement: Have Legal Requirements Changed?

Lathrop GPM on

One of the most notable developments in the anti-corruption world is the Trump Administration’s Feb. 10 Executive Order, “Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security.” ...more

Benesch

A Survey of Recent Enforcement Actions, Trends & Priorities

Benesch on

The landscape of criminal prosecution of foreign bribery has shifted, and the second Trump administration has made its priorities clear; however, companies still have 950 million reasons and counting to strengthen their...more

Stikeman Elliott LLP

Foreign Bribery: The Bottom Line is that It’s Still Illegal Under Canadian Law

Stikeman Elliott LLP on

It remains illegal under the Canadian Corruption of Foreign Public Officials Act (“CFPOA”) to bribe foreign officials. While this statement may be self-evident, recent developments south of the border prompt this reminder to...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

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