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Enforcement Guidance Anti-Corruption

Seyfarth Shaw LLP

Updated SFO Guidance: Familiar Framework, Sharper Focus—Timing Is Everything

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The Serious Fraud Office (SFO) is raising the stakes. With the publication of new Co-operation and Enforcement Guidance on 24 April 2025, the agency is ramping up enforcement and clarifying expectations for corporate...more

Jones Day

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

Jones Day on

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

Thomas Fox - Compliance Evangelist

Navigating Compliance in Interesting Times

I once had a boss whose catchphrase was ‘May you live in interesting times’. That applied back in the first decade of this century and I think it is even more appropriate now. In a world that often feels as if it is...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

WilmerHale on

Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

The Volkov Law Group

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

The Volkov Law Group on

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

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

The Volkov Law Group

DOJ Promoting Enforcement and Compliance Message

The Volkov Law Group on

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

Commerce Department Tacks to New Aggressive Enforcement Program

The Volkov Law Group on

The Commerce Department’s Bureau of Industry and Security (“BIS”) has decided to join the enforcement club.  BIS’s recent announcement of new policies to administrative actions should not be surprising.  ...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

Jenner & Block on

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

Jones Day on

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

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

Cozen O'Connor

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

Cozen O'Connor on

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

Hogan Lovells

The new Brexit deal: tougher times ahead for an already struggling SFO?

Hogan Lovells on

On 24 December 2020, the UK and the EU reached a new Trade and Cooperation Agreement. The deal, which came into force on 1 January 2021, has important implications for white collar crime enforcement across Europe, and in...more

K&L Gates LLP

DOJ Releases Its First FCPA Advisory Opinion Since 2014—What You Need to Know About the FCPA Advisory Opinion Process

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For the first time since 2014, the Department of Justice’s (DOJ) Foreign Corrupt Practices Act (FCPA) Unit has issued an opinion responding to a request for advice on compliance with the anti-bribery provisions of the FCPA. ...more

Polsinelli

A Long Time Coming: DOJ Issues First FCPA Advisory Opinion in Six Years

Polsinelli on

On August 14, 2020, the Department of Justice issued a Foreign Corrupt Practices Act (“FCPA”) Advisory Opinion—the first of its kind in nearly six years. The DOJ’s opinion advised a U.S. investment company that the...more

Cadwalader, Wickersham & Taft LLP

DOJ and SEC Update FCPA Resource Guide for 2020 – What’s New and What Does It Mean?

On July 3, 2020, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) updated their 2012 joint guidance on the Foreign Corrupt Practices Act (“FCPA”) in the SEC and DOJ’s FCPA Resource Guide...more

The Volkov Law Group

DOJ Tweaks FCPA Corporate Enforcement Policy

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The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more

Katten Muchin Rosenman LLP

Bridging the Week - March 2019 #2

Unexpectedly, the Commodity Futures Trading Commission announced a new initiative to encourage non-registrants to self-report foreign corrupt practices, which it claimed might also constitute violations of laws and rules it...more

A&O Shearman

CFTC Announces Further Incentives For Self-Reporting, Cooperation For Unregistered Individuals And Entities, While Highlighting...

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On March 6, 2019, the head of the U.S. Commodity Futures Trading Commission’s (“CFTC’s”) Enforcement Division, James McDonald, announced a new policy related to the benefits of self-reporting foreign corrupt practices-related...more

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