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Foreign Corrupt Practices Act (FCPA) Corporate Misconduct Enforcement Priorities

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”

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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

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

Wiley Rein LLP on

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

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

Lathrop GPM

Trump Executive Order Pausing FCPA Enforcement: Have Legal Requirements Changed?

Lathrop GPM on

One of the most notable developments in the anti-corruption world is the Trump Administration’s Feb. 10 Executive Order, “Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security.” ...more

Benesch

A Survey of Recent Enforcement Actions, Trends & Priorities

Benesch on

The landscape of criminal prosecution of foreign bribery has shifted, and the second Trump administration has made its priorities clear; however, companies still have 950 million reasons and counting to strengthen their...more

Latham & Watkins LLP

UK and European Considerations: President Trump Pauses FCPA Enforcement

Latham & Watkins LLP on

The executive order halts new and existing foreign bribery investigations — but enforcement risk in the UK and Europe remains. On February 10, 2025, President Trump issued an executive order titled “Pausing Foreign...more

Fenwick & West LLP

CLE Takeaways: 2025 Government Enforcement Priorities and Trends

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Businesses today must navigate an intricate web of policies, regulations, and enforcement actions that demand not only vigilance but a proactive stance toward transparency and cooperation....more

Dorsey & Whitney LLP

DOJ to Develop New Whistleblower Program to Augment Existing Federal Whistleblower Programs

Dorsey & Whitney LLP on

Last week Deputy Attorney General Lisa Monaco announced that the U.S. Department of Justice (DOJ) will soon begin a pilot program to reward whistleblowers who alert prosecutors to significant corporate misconduct. The goal of...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

Latham & Watkins LLP

DOJ’s Updated Corporate Enforcement Policy Aims to Incentivize Compliance

Latham & Watkins LLP on

Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more

Dorsey & Whitney LLP

DOJ Announces Additional Incentives for Corporate Cooperation in Criminal Enforcement

Dorsey & Whitney LLP on

On January 17, 2023, Assistant Attorney General for the United States Department of Justice Kenneth A. Polite Jr. announced significant revisions to the Criminal Division’s Corporate Enforcement Policy (“CEP”). Four months...more

Womble Bond Dickinson

DOJ Raises Stakes on Corporate Compliance: How to Respond

Womble Bond Dickinson on

Even at companies with separate legal and compliance departments, Department of Justice-enforced compliance is a key concern for in-house counsel. Those pressures only will increase in the near future and are rapidly...more

Womble Bond Dickinson

DOJ Announcements on Corporate Criminal Enforcement: Defining the Carrots and Sticks

Womble Bond Dickinson on

The Department of Justice (DOJ) has been touting revisions to its corporate criminal enforcement policies and signaling increased action for nearly a year. Yesterday, Deputy Attorney General Lisa O. Monaco formally announced...more

Womble Bond Dickinson

“Carrots & Sticks”: Individual Accountability in Corporate Criminal Enforcement Remains a Top DOJ Priority

Womble Bond Dickinson on

On March 3, 2022, at the 37th Annual American Bar Association Criminal Justice Section National Institute on White Collar Crime in San Francisco, Attorney General Merrick B. Garland emphasized that “the prosecution of...more

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