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Bribery Foreign Corrupt Practices Act (FCPA) National Security

Hogan Lovells

DOJ's pause on FCPA is a compliance shake up for businesses

Hogan Lovells on

This article was originally published by Bloomberg Law on April 10, 2025, and is republished here with permission. Read the original article here: DOJ’s Pause on FCPA Is a Compliance Shake-Up for Businesses – Bloomberg Law. ...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

Womble Bond Dickinson

Compliance Still Matters: The Future of FCPA Enforcement

Womble Bond Dickinson on

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

Mayer Brown

US DOJ Outlines New Enforcement Priorities for Corporations and Individuals

Mayer Brown on

On Wednesday, February 5, 2025, the newly confirmed Attorney General (AG) Pam Bondi issued fourteen memoranda to all Department of Justice (DOJ or the “Department”) employees regarding a wide range of new policies and...more

Wiley Rein LLP

[Podcast] The Iron Fist of General Sani Abacha, Nigeria's Ruthless Dictator

Wiley Rein LLP on

Join hosts Tatiana Sainati and Diana Shaw as they delve into the gripping story of General Sani Abacha, the Nigerian dictator who embezzled billions of dollars and ruled with an iron fist from 1993 to 1998. Known for his...more

Foley & Lardner LLP

Business Impacts of Trump’s Executive Order Pausing FCPA Enforcement

Foley & Lardner LLP on

On February 10 President Trump issued an Executive Order, Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security, signaling a shift in U.S. enforcement priorities regarding...more

Hogan Lovells

Criminal FCPA enforcement paused. Now what?

Hogan Lovells on

On February 10, 2025, President Trump ordered the U.S. Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) and issue new enforcement guidelines that take into consideration U.S....more

BakerHostetler

Why Your Company Still Needs to Care About the FCPA (& FEPA)

BakerHostetler on

This shift in FCPA enforcement priorities is the latest move by the administration in its all-out war against cartels and TCOs that pose a threat to U.S. national security and its stated America First agenda. Additionally,...more

Baker Botts L.L.P.

Yes, Bribes Are Still Illegal, and Other Takeaways from the Pause on Foreign Corrupt Practices Act Enforcement

Baker Botts L.L.P. on

On February 10, 2025 President Trump issued an executive order titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” The order directs the DOJ to halt Foreign Corrupt...more

The Volkov Law Group

Taking Stock of the FCPA Fallout (Part III of V)

The Volkov Law Group on

What an amazing turn of events? — Who would have predicted that the Trump Administration would take such a bold action in the name of advancing “American Competitiveness.” I admit I did not see this coming — the Trump...more

DLA Piper

President Trump’s Executive Order Pauses FCPA Enforcement Pending Attorney General Review

DLA Piper on

On February 10, 2025, President Donald Trump signed an Executive Order (EO) directing Attorney General (AG) Pam Bondi to pause enforcement of the Foreign Corrupt Practices Act (FCPA) until new enforcement guidelines and...more

Kilpatrick

President Trump Hits "Pause" (But Not "Stop"): The Scope of the New Executive Order on The DOJ's FCPA Enforcement Against American...

Kilpatrick on

Key Takeaways: The Executive Order’s 180-day pause on the DOJ’s FCPA enforcement does not eliminate many corruption and bribery risks. The Executive Order is limited in that it does not currently affect enforcement by...more

Katten Muchin Rosenman LLP

President Trump Pauses FCPA Enforcement

On February 10, 2025, President Donald Trump issued an Executive Order titled "Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security" (the "E.O."). The E.O was issued five days...more

Ropes & Gray LLP

Enforcement under the Trump Administration: Reports of the FCPA’s Death are Exaggerated

Ropes & Gray LLP on

On February 10, 2025, President Trump issued an executive order (the “EO”) directing the U.S. Department of Justice (“DOJ”) to pause new Foreign Corrupt Practices Act (“FCPA”) investigations and enforcement actions for 180...more

The Volkov Law Group

Lessons Learned from the SAP Enforcement Action — DOJ Changes Tack on FCPA Enforcement While SEC Digs into Third-Party Controls...

The Volkov Law Group on

A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you.  I know I am scratching my head trying to make sense of the whole picture here.  There are a number of significant indicators of a...more

BakerHostetler

Congress Expands DOJ’s Power to Prosecute Corruption with the Foreign Extortion Prevention Act

BakerHostetler on

Adding to federal prosecutors’ tool kit in fighting global corruption, on December 14, 2023, Congress passed with bipartisan support, the Foreign Extortion Prevention Act (FEPA). As part of the National Defense Authorization...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for August 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

Goodwin

2021 Year in Review: FCPA

Goodwin on

A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

Kramer Levin Naftalis & Frankel LLP

Biden Administration Issues Directive for Revitalized Strategies to Combat Corruption and Financial Crime, Signaling Increased...

On June 3, 2021, President Biden issued the first National Security Study Memorandum of his presidency, in which he declared fighting corruption “a core United States national security interest.” The Memorandum sets out the...more

A&O Shearman

Airbus Agrees Record-Breaking €3.6 Billion Settlement to Avoid Prosecution

A&O Shearman on

On 31 January 2020, Airbus SE (Airbus) reached final agreements with the French Parquet National Financier (PNF), the U.K.’s Serious Fraud Office (SFO) and the U.S. Department of Justice (DoJ) in order to resolve...more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 6 – The Investigation, the Remediation and Final Thoughts

Over the past several blog posts, I have been exploring the Airbus SE (Airbus) international anti-corruption settlement in some depth. One of the questions I have had and hopefully raised for readers is not why the overall...more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 5 – The UK Judgment on the DPA

Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more

The Volkov Law Group

Airbus Systemic Bribery and Export Violations: Understanding How a Company’s Compliance Program and Culture Failed (Part IV of IV)

The Volkov Law Group on

When reviewing a major enforcement case, I always ask two basic questions: What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance?...more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 4 – Alphabet Agency Violations (Export Control and Export Finance)

Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more

The Volkov Law Group

Airbus ITAR Settlement: Review of Airbus ITAR Violations (Part III of IV)

The Volkov Law Group on

The Justice Department has brought only a few enforcement actions that focus on FCPA and export control violations.  Last year, Quad Graphics earned a declination for FCPA and OFAC violations.  In 2013, Weatherford settled...more

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