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Enforcement Actions Foreign Corrupt Practices Act (FCPA) Regulatory Reform

Morgan Lewis

Securities Enforcement Roundup – June 2025

Morgan Lewis on

In this issue of our monthly Securities Enforcement Roundup, we highlight top securities enforcement developments from June 2025. In June 2025: Overall, we continue to see the SEC and other regulators focus on interactions...more

Husch Blackwell LLP

Updated: Trump Administration Clarifies Criminal Enforcement Priorities

Husch Blackwell LLP on

On May 9, 2025, the White House issued an executive order, titled “Fighting Overcriminalization in Federal Regulations,” that could have a significant impact on the administration’s enforcement of criminal regulatory...more

Herbert Smith Freehills Kramer

US Corporate Governance — 2025 Midyear Review

The Financial Crimes Enforcement Network (FinCEN) issued an interim final rule in March 2025 that removes requirements for US companies to report beneficial ownership information under the Corporate Transparency Act (CTA)....more

Dickinson Wright

QuickHits: DOJ’s FCPA Shift and Impacts on U.S.-China Operations

Dickinson Wright on

Welcome to QuickHits. This brief newsletter covers recent cases, legal developments, and key questions affecting the evolving U.S.-China relationship and related business and legal environments. It’s produced by attorneys...more

Baker Donelson

Update: DOJ Issues Guidelines for Protectionist FCPA Enforcement

Baker Donelson on

In February, the White House issued an Executive Order "pausing" Foreign Corrupt Practices Act (FCPA) enforcement for 180 days, to "further American economic and national security."1 On June 9, Deputy Attorney General Todd...more

Jones Day

DOJ Resumes FCPA Enforcement Under New Guidelines Prioritizing the Protection of American Interests

Jones Day on

In response to President Trump's February 10, 2025, Executive Order pausing DOJ FCPA enforcement (the "Executive Order"), on June 9, 2025, the DOJ issued new guidelines (the "Guidelines"), which prioritize the enforcement of...more

Porter Hedges LLP

DOJ Issues New Guidelines Narrowing FCPA Enforcement Scope

Porter Hedges LLP on

On June 9, 2025, the Department of Justice (DOJ) released updated guidelines governing the enforcement of the Foreign Corrupt Practices Act (FCPA), signaling a more focused and strategic approach to foreign bribery cases. The...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

Perkins Coie

FCPA Is Here to Stay: DOJ Reaffirms Commitment to Enforce FCPA

Perkins Coie on

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

Lowenstein Sandler LLP

The End of 180 Days of Uncertainty? DOJ Closes Current FCPA Investigations, Issues New Guidelines for FCPA Enforcement

Lowenstein Sandler LLP on

On June 9, Deputy Attorney General Todd Blanche issued a memorandum (the Memorandum) outlining revised guidelines for investigation and enforcement of the Foreign Corrupt Practices Act (FCPA). The U.S. Department of Justice...more

Thomas Fox - Compliance Evangelist

Compliance into the Weeds: Changes in FCPA Enforcement

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting...more

Morgan Lewis

DOJ Issues Anticipated FCPA Enforcement Guidelines with Focus on US Interests, Individual Accountability

Morgan Lewis on

The US Department of Justice has issued new guidance regarding enforcement of the Foreign Corrupt Practices Act (FCPA) in a June 9 memorandum from Deputy Attorney General Todd Blanche. The memorandum formalizes a shift in...more

Thomas Fox - Compliance Evangelist

Compliance into the Weeds: Changes in FCPA Enforcement

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting...more

Vinson & Elkins LLP

Focus, Fairness, & Efficiency: DOJ White Collar Policy Shifts Signal Recalibration, But Not Revolution in Enforcement

Vinson & Elkins LLP on

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (“DOJ” or the “Department”) issued a series of significant policy changes outlining the Trump administration’s new approach to white-collar enforcement....more

Hogan Lovells

DOJ corporate enforcement overhaul: More declinations, fewer monitors, and FCPA enforcement still in question

Hogan Lovells on

On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to key corporate criminal enforcement policies. The revisions’ stated aim is to provide more clarity and certainty of outcome to companies that...more

DLA Piper

The Second Trump Administration’s First 100 days

DLA Piper on

The first 100 days of the second Trump Administration have been marked by a flurry of Executive Orders (EOs) and policy memoranda intended to advance President Donald Trump’s “America First” agenda. In the process, these...more

DLA Piper

Key Considerations for Compliance Officers Under President Trump

DLA Piper on

The Trump Administration has ushered in massive shifts in enforcement and policy priorities. From crypto to anti-corruption measures and tariffs to technology, the new Administration has changed the compliance landscape...more

Hogan Lovells

Brazil – a new ally for the enforcement avengers? Brazil collaborating with China on anti-corruption enforcement

Hogan Lovells on

At a legal industry event on 9 April 2025, Marcelo Pontes Vianna, the head of the secretariat for private integrity of Brazil's Office of the Comptroller General (CGU), the national antibribery agency, highlighted Brazil's...more

White & Case LLP

SEC Enforcement 2.0: Chairman Atkins Has Arrived

White & Case LLP on

Paul Atkins has taken the reins of the US Securities and Exchange Commission (SEC). After being confirmed by the Senate on April 9, Atkins officially began his tenure as SEC Chairman on April 21. His arrival is expected to...more

Hinshaw & Culbertson - Consumer Financial...

An In-House Compliance Guide for Responding to President Trump's Executive Order on Foreign Corrupt Practices Act Enforcement

As has widely been published, on February 10, 2025, President Trump signed Executive Order (EO) 14209, which paused all future investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA) for at least...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

Torres Trade Law, PLLC

President Trump Pauses FCPA Enforcement

On February 10, 2025, President Trump issued an Executive Order on “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security” (“the E.O.”). The E.O. orders Attorney General, Pam...more

Seyfarth Shaw LLP

Navigating Trump’s FCPA Enforcement Pause: Strategic Recommendations for Corporate Leaders

Seyfarth Shaw LLP on

President Trump’s February 10th Executive Order (EO) titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security,” has introduced significant uncertainty into FCPA enforcement....more

Carlton Fields

President Trump Issues Executive Order Pausing Enforcement of FCPA: A Sea Change Moment for DOJ and SEC

Carlton Fields on

On February 10, 2025, President Trump issued Executive Order 14209, titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security,” with the stated purpose of eliminating...more

Latham & Watkins LLP

Executive Order Pauses FCPA Enforcement at DOJ: Key Takeaways on Immediate Impact

Latham & Watkins LLP on

Insights and open questions for companies seeking to promote anti-corruption compliance in a dynamic regulatory environment. On February 10, 2025, the Trump administration issued an executive order (the Order) taking aim...more

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