News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Corporate Misconduct

Wiley Rein LLP

DOJ’s Approach to White Collar Enforcement: Target Those Who Harm U.S. Interests While Minimizing Collateral Damage

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The U.S. Department of Justice (DOJ) recently announced Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA). The June 9 memorandum from Deputy Attorney General Todd Blanche instructs...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

Bracewell LLP

DOJ’s New FCPA Investigations and Enforcement Guidelines: How Organizations Need to Respond

Bracewell LLP on

The Deputy Attorney General of the U.S. Department of Justice Office recently issued new guidelines for investigations and enforcement actions of the Foreign Corrupt Practices Act. (FCPA). These new guidelines come as a first...more

Latham & Watkins LLP

DOJ Focuses FCPA Enforcement With New Guidelines

Latham & Watkins LLP on

DOJ issues updated guidelines, ending temporary “pause” on FCPA enforcement and focusing potential enforcement on priority areas. On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the Guidelines)...more

Compliance and Ethics: Ideas & Answers

The First US Law School Course on Compliance: Its Origins and Evolution

This essay traces the origin and development of the first dedicated law school course on corporate compliance and ethics programs in the United States. Responding to legal and practice developments over the last two decades,...more

Herbert Smith Freehills Kramer

DOJ resumes FCPA enforcement with new guidelines

On June 10, 2025, the head of the Criminal Division of the Department of Justice (DOJ), Matthew Galeotti, declared in a speech that the DOJ would resume enforcing the Foreign Corrupt Practices Act (FCPA). This announcement...more

Venable LLP

FCPA Enforcement Resumes with New Guidelines Focused on Strategic U.S. Interests

Venable LLP on

The pause on enforcement of the Foreign Corrupt Practices Act (FCPA) is over. On June 9, the Deputy Attorney General of the Department of Justice (DOJ) issued a memorandum (the June 9 Memorandum) establishing new enforcement...more

BakerHostetler

FCPA Enforcement Is Back with a New Enhanced Focus on Protecting US Business Abroad, National Security, Individuals and (of...

BakerHostetler on

U.S. Department of Justice (DOJ) Deputy Attorney General Todd Blanche issued a memorandum on June 9 (the Memo), announcing DOJ will resume enforcement of the Foreign Corrupt Practices Act (FCPA) after its brief hiatus....more

Ballard Spahr LLP

Focused FCPA Enforcement: Emphasizing Security and Strategic Interests

Ballard Spahr LLP on

On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the DAG memorandum) updating the Department of Justice’s (DOJ) enforcement guidelines for the Foreign Corrupt Practices Act (FCPA) in accordance with...more

Ropes & Gray LLP

DOJ’s New FCPA Playbook: “Time To Get To Work”

Ropes & Gray LLP on

On June 9, 2025, the U.S. Department of Justice (“DOJ” or the “Department”) issued the highly anticipated guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (“FCPA”) (“FCPA Guidelines”),...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

DarrowEverett LLP

The DOJ’s New White-Collar Agenda: Implications for Businesses

DarrowEverett LLP on

On May 12, 2025, the Department of Justice (the “DOJ”) released its criminal—and, more specifically, white collar crime enforcement—initiatives under the current administration. This is typical each time new leadership...more

Woods Rogers

DOJ's Updated Playbook: New Rules for White-Collar Enforcement

Woods Rogers on

On May 12, 2025, the Criminal Division of the Department of Justice (DOJ) issued a memorandum outlining a recalibrated approach to white-collar criminal enforcement. The memorandum, titled “Focus, Fairness, and Efficiency in...more

Benesch

Compliance and Self-Disclosure of Misconduct Must be Top Priorities for Corporate Organizations, According to New Guidance from...

Benesch on

On May 12, 2025, Assistant Attorney General Matthew R. Galeotti, head of the U.S. Department of Justice’s Criminal Division, issued a new policy memorandum entitled “Focus, Fairness, and Efficiency in the Fight Against...more

McCarter & English, LLP

DOJ Criminal Division Announces White Collar Enforcement Priorities and Policy Changes to White Collar Investigations

Earlier this week, the US Department of Justice (DOJ) released a new white collar enforcement plan (Enforcement Plan) outlining changes to the Criminal Division’s white collar enforcement priorities to align more closely with...more

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

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

Ropes & Gray LLP

Department of Justice Announces Changes to Corporate Enforcement Policies; More Carrots and Sticks

Ropes & Gray LLP on

On May 12, 2025, at SIFMA’s annual Anti-Money Laundering and Financial Crimes Conference, the U.S. Department of Justice’s Criminal Division Chief announced a new White-Collar Enforcement Plan and accompanying changes to...more

Womble Bond Dickinson

DOJ Announces Key Corporate Enforcement Changes & White-Collar Priorities

Womble Bond Dickinson on

DOJ recently announced white-collar crime enforcement priorities and significant changes to its corporate enforcement policies (here and here). “[O]verbroad and unchecked corporate and white-collar enforcement burdens U.S....more

White & Case LLP

Ten Takeaways from the DOJ Criminal Division’s New Playbook on White Collar Enforcement Priorities

White & Case LLP on

On May 12, 2025, the U.S. Department of Justice ("the DOJ" or "the Department") unveiled its new playbook for prosecuting white-collar and corporate crime. DOJ announced enforcement priorities for the Criminal Division ("the...more

Akin Gump Strauss Hauer & Feld LLP

DOJ’s Criminal Division Turns Page on White Collar Crime—But Keeps One Foot in the Past

On May 12, 2025, the DOJ announced a new “white-collar enforcement plan” identifying new corporate enforcement priorities and aiming to promote greater focus, fairness and efficiency in prosecuting corporate misconduct. In a...more

Wiley Rein LLP

DOJ Announces Changes to White Collar Enforcement Policies, Focusing on “Most Egregious” Crimes

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This week, the U.S. Department of Justice (DOJ) announced the Criminal Division’s new white collar enforcement plan, changes to its Corporate Whistleblower Pilot Program, and revisions to the Corporate Enforcement and...more

Gray Reed

Bad Guys in Energy Paid the Piper in 2024

Gray Reed on

As in every year, in 2024 the grinches of law enforcement brought financial and corporal misery to bad guys in energy. Here is a review of the crimes of only a few of the convicted, admitted and alleged bribsters, swindlers...more

WilmerHale

DOJ Announces White Collar Enforcement Priorities and Revisions to Related Policies

WilmerHale on

On May 12, 2025, Matthew Galeotti, the Head of the Criminal Division at the Department of Justice ("DOJ") issued a new white collar enforcement plan (“Enforcement Plan”) titled “Focus, Fairness, and Efficiency in the Fight...more

Miles & Stockbridge P.C.

Despite Reduced Enforcement Risks, Businesses Should Invest in Corporate Compliance

Some early actions by the Trump administration have led corporate legal departments to question the extent to which they need to invest in ethics and compliance at this time, based on a perceived reduction in enforcement...more

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