News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Cooperation Criminal Prosecution

BakerHostetler

The DOJ Announces Administration’s Revised Corporate Enforcement Strategy

BakerHostetler on

On May 12, 2025, Matthew Galeotti, Head of the Department of Justice’s (DOJ) Criminal Division, unveiled a comprehensive white collar enforcement strategy titled “Focus, Fairness, and Efficiency in the Fight Against...more

Fenwick & West LLP

DOJ Announces Key Revisions to Corporate Enforcement and Voluntary Self-Disclosure Policy

Fenwick & West LLP on

On May 12, 2025, the Head of the Department of Justice’s (DOJ) Criminal Division, Matthew Galeotti, announced a new white collar enforcement plan in a memorandum entitled “Focus, Fairness, and Efficiency in the Fight Against...more

BakerHostetler

The Lines Are Open! DOJ Adds New Tool in Anticorruption Efforts With Whistleblower Pilot Program

BakerHostetler on

Building on the recent passage of the Foreign Extortion Prevention Act (FEPA), at the American Bar Association’s 2024 National Institute on White Collar Crime conference in San Francisco earlier this month (2024 ABA...more

BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

BakerHostetler on

At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Compelled Interviews Admissible in Criminal Prosecution Against Former Company President and Its General Counsel

A New Jersey federal court has ruled that a company’s self-disclosure of potential Foreign Corrupt Practices Act (FCPA) violations did not render the company a state actor, allowing evidence obtained by its internal...more

McDermott Will & Emery

DOJ Revamps Corporate Criminal Enforcement Policies with Continued Emphasis on Compliance

McDermott Will & Emery on

At a September 15, 2022, speech at New York University School of Law, US Deputy Attorney General (Deputy AG) Lisa Monaco announced several new policies intended to further the aggressive stance the US Department of Justice...more

WilmerHale

Análisis Anual sobre Prácticas Anticorrupción en América Latina: Desarrollos del 2021 y Predicciones para el 2022

WilmerHale on

Aunque la cantidad de casos relacionados con la Ley de Prácticas Corruptas en el Extranjero (Foreign Corrupt Practices Act, FCPA) resueltos públicamente en el año 2021 fue relativamente baja en comparación con los años...more

WilmerHale

Latin America Anti-Bribery Year-in-Review: 2021 Developments and Predictions for 2022

WilmerHale on

Although the number of publicly resolved Foreign Corrupt Practices Act (FCPA) cases in 2021 was relatively low compared to prior years, enforcement actions related to Latin America played a particularly prominent role. Many...more

WilmerHale

Latin America Anti-Bribery Year-in-Review: 2020 Developments and Predictions for 2021 (Spanish version)

WilmerHale on

A pesar de los impactos de la pandemia del COVID-19, 2020 fue un año activo no solo para la aplicación de la Ley de Prácticas Corruptas Extranjeras (Foreign Corrupt Practices Act, FCPA), sino también para la lucha contra la...more

WilmerHale

Latin America Anti-Bribery Year-in-Review: 2019 Developments and Predictions for 2020

WilmerHale on

Foreign Corrupt Practices Act (FCPA) enforcement activity reached new heights in 2019. Corporate penalties paid to US enforcement agencies topped last year’s record levels, and individuals were charged at a pace matching last...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - December 2019

IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more

WilmerHale

Airbus to Pay Record $4 Billion to Settle Global Bribery Scheme

WilmerHale on

On January 31, 2020, the Department of Justice (“DOJ”) agreed to resolve allegations that Airbus SE (“Airbus”), a France-based aerospace company, used third-party business partners to bribe government officials and airline...more

WilmerHale

Commodity Futures Trading Commission - 2019 in Review: CFTC 2019 Enforcement and Regulatory Developments and a Look Forward

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In 2019, the Commodity Futures Trading Commission (CFTC or Commission) experienced significant changes in leadership, including the appointment of Dr. Heath P. Tarbert as the Commission’s 14th Chairman. The Division of...more

WilmerHale

$1 Billion Ericsson Resolution, Three Jury Verdicts Cap Off Busy Fourth Quarter for US FCPA Enforcement

WilmerHale on

On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more

Butler Snow LLP

2019 Developments and Trends in the Foreign Corrupt Practices Act (FCPA) & Global Anti-Corruption Efforts, Part 2 of 3

Butler Snow LLP on

Previously, we introduced you to this topic and provided updates about the positive international trends in anti-corruption efforts, bribery, and the Organization for Economic Cooperation and Development (OECD). Today, we...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - June 2019

ANTICORRUPTION DEVELOPMENTS - Deputy Assistant Attorney General Matt Miner Delivers Remarks at the American Bar Association, Criminal Justice Section Third Global White Collar Crime Institute Conference - On June 27,...more

McDermott Will & Emery

Assistant AG Provides Clarity on FCPA Self-Disclosure Credit

McDermott Will & Emery on

Assistant Attorney General Brian Benczkowski’s remarks provide important guidance for management and boards, and underscore the US Department of Justice’s commitment to prosecuting individuals for corporate misconduct....more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: DOJ Policies Aim to Reduce Enforcement Burden on Cooperating Entities

The Department of Justice (DOJ) appears to be continuing to revamp its approach to companies suspected of financial crimes, and emphasize the importance of prosecutions of individuals. In a number of speeches in 2018, senior...more

WilmerHale

Foreign Corrupt Practices Act Alert: Global Anti-Bribery Year-in-Review: 2018 Developments and Predictions for 2019

WilmerHale on

Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more

BakerHostetler

Revised DOJ Corporate Cooperation Policy Paints a Target on Individuals

BakerHostetler on

Last week, at the American Conference Institute’s 35th International Conference on the Foreign Corrupt Practices Act, Deputy Attorney General Rod Rosenstein introduced revisions to the Department of Justice’s (DOJ)...more

WilmerHale

DOJ Announces Revisions to Policy on Corporate Cooperation

WilmerHale on

In a November 29, 2018 speech, Deputy Attorney General Rod Rosenstein announced a softening of the US Department of Justice’s (DOJ) policy on giving credit for cooperation in corporate prosecutions. As memorialized in the...more

Eversheds Sutherland (US) LLP

US Department of Justice relaxes Yates Memorandum’s requirements for earning cooperation credit

On November 29, 2018, the US Department of Justice (DOJ) modified prior guidance on individual liability for corporate misconduct by affording federal prosecutors discretion to focus on “individuals who play significant roles...more

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

Holland & Knight LLP on

• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more

Bradley Arant Boult Cummings LLP

DOJ Announces New Policy about “Piling On” and Discusses the Role of Compliance in Corporate Enforcement - Government Enforcement...

In a pair of recent speeches, Deputy Attorney General Rod Rosenstein announced a new Department of Justice (DOJ) policy aimed at encouraging coordination among DOJ and other enforcement agencies and avoiding “unfair...more

Holland & Knight LLP

Obedient Companies Rewarded in New DOJ Policy Discouraging Duplicative Penalties

Holland & Knight LLP on

• Deputy Attorney General Rod Rosenstein has announced a new U.S. Department of Justice (DOJ) policy to discourage government agencies from "piling on" duplicative corporate penalties. • Rosenstein signaled a desire for...more

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