News & Analysis as of

Corruption Enforcement Guidance

DLA Piper

DOJ’s Revised Policy on Crediting Fines: Emphasis on Victims

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Without fanfare, the Department of Justice (DOJ or the Department) has published a memorandum revising its policy on when – and how – it will give credit to companies for fines and other payments made to other agencies,...more

Nossaman LLP

DOJ Issues New FCPA Enforcement Guidelines

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New factors for investigating and enforcing the Foreign Corrupt Practices Act were recently released by head of the Criminal Division of the U.S. Department of Justice (DOJ) in, “Guidelines for Investigations and Enforcement...more

Katten Muchin Rosenman LLP

Updated FCPA Guidance

Shortly after taking office President Trump signed an executive order titled, “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.” Among other things, President Trump...more

Alston & Bird

FCPA Pause, We Hardly Knew Ye: The DOJ Issues New FCPA Enforcement Guidance

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Our White Collar, Government & Internal Investigations Team analyzes new guidance from the Department of Justice that signals continued—and potentially heightened—enforcement of the Foreign Corrupt Practices Act....more

Carlton Fields

Shifting Priorities in White Collar Enforcement: May 2025 DOJ Memo and What It Means for Companies

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On May 12, 2025, the Department of Justice (DOJ) Criminal Division announced significant changes in its policies on investigating and prosecuting white collar crime, including a shift in focus toward several areas deemed to...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

Dorsey & Whitney LLP

Should Your Company Shut Down Its Anti-Corruption Compliance Program and Start Paying Bribes? Here Are a Few Reasons to Think...

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On February 10, 2025, President Trump issued a new Executive Order (“EO”) titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” This EO comes on the tail of Attorney...more

Latham & Watkins LLP

President Trump Issues Executive Order Pausing Foreign Corrupt Practices Act Enforcement at DOJ

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The order pauses new FCPA criminal cases, directs review of existing cases, and leaves open several questions, including implications for specific business sectors and civil enforcement....more

Thomas Fox - Compliance Evangelist

The DOJ on the Need for Compliance Program Data Analytics

The Department of Justice (DOJ) is increasingly utilizing data analytics for proactive enforcement, signaling a significant shift in their approach to combating white-collar crime. This move reflects the recognition of data...more

The Volkov Law Group

Corsa Coal Earns Declination and Agreed to Disgorge $1.2 Million

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The Justice Department has been pushing its voluntary self-disclosure program and changes to its Corporate Enforcement Policy, in an attempt to increase FCPA enforcement cooperation.  The Golden Ring for every company facing...more

Jones Day

French National Financial Prosecutor's Office Publishes New Guidelines on Judicial Conventions of Public Interest

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The new guidelines update those published jointly by the National Financial Prosecutor's Office (Parquet National Financier or "PNF") and the French Anticorruption Agency (Agence Française Anticorruption or "AFA") on June 26,...more

Jones Day

DOJ Criminal Division Announces Revisions to its Corporate Enforcement Policy

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In Short - The Situation: On January 17, 2023, the U.S. Department of Justice ("DOJ" or "Department") announced significant revisions to the Criminal Division's Corporate Enforcement Policy....more

Hogan Lovells

DOJ sets forth new incentives for companies to self-disclose and cooperate

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On January 17, 2023, the Department of Justice (DOJ) rolled out revisions to its Corporate Enforcement Policy (CEP) aimed at incentivizing companies to voluntarily self-disclose misconduct and to cooperate with government...more

The Volkov Law Group

DOJ Promoting Enforcement and Compliance Message

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Contrary to the often-repeated narrative, the Justice Department is transparent about its enforcement plans and compliance expectations.  Since the issuance of the FCPA Guidance in 2012, DOJ has continued to provide guidance...more

The Volkov Law Group

ABB – A Three-Time Loser – Settles FCPA Case for Bribery in South Africa for $315 Million (Part I of III)

The Volkov Law Group on

The Justice Department’s new Corporate Enforcement Policy and the heightened enforcement and compliance expectations were put to the test in its announcement of a $315 million settlement of bribery charges with ABB, a...more

The Volkov Law Group

United States Slaps Additional Sanctions on Russia Against Luxury Goods

The Volkov Law Group on

Keeping up with the Russia Sanctions and Export Controls is a challenge.  Each day a new sanction or restriction is adopted with ripple actions by United States Allies and partners....more

The Volkov Law Group

The United States Strategy on Countering Corruption: Digging into the Anti-Corruption Initiatives (Part III of III)

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The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals.  ...more

The Volkov Law Group

The Five Pillars of the New Anti-Corruption Initiative (Part II of III)

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The Biden Administration’s new anti-corruption initiative is a significant commitment to the battle against global corruption. According to the Biden Administration, “[c]orruption is a cancer with the body of societies – a...more

The Volkov Law Group

Biden Administration Announces New Anti-Corruption Strategy (Part I of III)

The Volkov Law Group on

The Biden Administration announced a new, comprehensive anti-corruption program, the United States Strategy on Countering Corruption. The new anti-corruption policy is the follow on to the earlier announcement elevating the...more

Jenner & Block

The Biden Administration’s Aggressive Policy Changes to Combat Corruption

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This week, the Biden Administration took a series of steps showing that anti-corruption issues across the globe will be among its highest priorities. On December 6, 2021, the Biden Administration unveiled the first ever...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Biden Administration Increases Efforts In Corruption Fight

Takeaway - Given the Biden Administrations National Security Study Memorandum, as well as the easing of the COVID-19 pandemic, it is now an opportune time for companies to review their compliance protocols and training in...more

Jones Day

SEC Awards $28 Million+ to Whistleblower for Tip Relating to 2018 FCPA Settlements

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On May 19, 2021, the SEC announced an award of more than $28 million to a whistleblower whose tip led the SEC and the DOJ to reach a combined $281 million FCPA settlement with a U.S.-based manufacturer of electronic systems...more

Jones Day

President Biden Declares Anticorruption Efforts a Core U.S. National Security Interest

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On June 3, 2021, President Biden issued a memorandum declaring anticorruption efforts to be "a core United States national security interest" and announcing a plan to "significantly bolster" anticorruption enforcement. While...more

Herbert Smith Freehills Kramer

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

Cozen O'Connor

A Dramatic Shift in Combatting International Corruption May Be on the Horizon

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On June 3, 2021, the White House issued a National Security Memorandum, in which President Biden identified countering corruption as a “core” U.S. national security interest. The President directed the Assistant to the...more

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