News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Criminal Investigations Anti-Corruption

Womble Bond Dickinson

Compliance Still Matters: The Future of FCPA Enforcement

Womble Bond Dickinson on

On January 20, President Trump issued an Executive Order designating certain international cartels as Foreign Terrorist Organizations (FTOs) or Specially Designated Global Terrorists (SDGTs). ...more

Troutman Pepper Locke

Key Considerations After DOJ Announces Shifting Enforcement Priorities

Troutman Pepper Locke on

On February 5, U.S. Attorney General (AG) Pam Bondi issued 14 memoranda to Department of Justice (DOJ) employees framing the DOJ's current policies and enforcement priorities. These shifting enforcement priorities are aligned...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

The Volkov Law Group

Tracking FCPA Individual Enforcement

The Volkov Law Group on

While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more

Thomas Fox - Compliance Evangelist

The Foreign Corrupt Practices Handbook: Interview with the Authors

I recently spoke with the Foreign Corrupt Practices Act (FCPA) Handbook authors Robert Tarun and Peter Tomczak from Baker McKenzie for a two-part podcast episode. The depth of knowledge and experience in white-collar crime,...more

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 3-the Discounted Fine

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 2, the Need for Speed

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Morrison & Foerster LLP

MoFo's 2023 FCPA Year in Review

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, our Foreign Corrupt Practices Act (FCPA) Year In Review provides quick, visual representations of key trends in FCPA enforcement over...more

Ballard Spahr LLP

DOJ Bolsters International Cooperation to Combat Corruption

Ballard Spahr LLP on

Summary - The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...more

The Volkov Law Group

DOJ Repeats Warnings on Aggressive Criminal Enforcement of Sanctions and Export Controls

The Volkov Law Group on

As everyone knows, I tend to repeat myself — DOJ does as well.  Over the past year, DOJ has warned global companies — over and over — about the coming criminal enforcement storm against companies for sanctions and export...more

The Volkov Law Group

Ericsson Settles Breach of 2019 FCPA Deferred Prosecution Agreement: Agrees to Plead Guilty, Pay $206 Million, and Extend...

The Volkov Law Group on

Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty.  In 2019, Ericsson entered...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for January 2023

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Foley Hoag LLP

CEP Revisions Incentivize “Extraordinary” Corporate Cooperation

Foley Hoag LLP on

Earlier in January 2023, the U.S. Department of Justice (DOJ) announced revisions to its Corporate Enforcement Policy (CEP) under the Foreign Corrupt Practices Act (FCPA) for the first time since 2017. In his speech...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for September 2022

Morrison & Foerster LLP on

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and case developments from the past month,...more

The Volkov Law Group

DOJ Puts its New Stamp on FCPA Settlements: Unraveling the Glencore FCPA Settlement (Part II of V)

The Volkov Law Group on

The Justice Department has been promising a new, more aggressive approach to FCPA enforcement.  DOJ officials have made statements to that effect on numerous occasions.  The Biden Administration touted its elevation of the...more

Morgan Lewis

DOJ Ramping Up Fraud Enforcement Efforts: 2021 Year in Review Report

Morgan Lewis on

The US Department of Justice’s Criminal Division Fraud Section released its annual Year in Review report on February 15, covering 2021. Despite ongoing aftershocks associated with the global pandemic, this year’s report...more

Guidepost Solutions LLC

With Enforcement Actions Likely to Increase in 2022, Companies Should Ask Where the Bodies are Buried

In 2022, companies are likely to see an increase in white collar and regulatory investigations and enforcement actions. Here are just a few reasons why this is likely to happen. First, in the late fall, Deputy Attorney...more

Goodwin

2021 Year in Review: FCPA

Goodwin on

A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2021

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption developments from the past month, with links to...more

Hogan Lovells

Happy Birthday! Ten takeaways as we chart the tenth birthday of the UK Bribery Act

Hogan Lovells on

On 1 July 2021, the UK Bribery Act (the Act) – one of the world’s global bribery and corruption benchmark laws – turns 10. It’s been an eventful 10 years: the Serious Fraud Office (SFO), the Act’s primary enforcement agency,...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Operation Car Wash Leads To FCPA Conviction

U.S. companies doing business in Latin America must ensure that they institute and maintain strong anti-corruption safeguards. These companies must be prepared to coordinate with regulators from multiple jurisdictions in the...more

Miller Canfield

Record Level of FCPA Enforcement in 2020 Highlights Key Risk Areas

Miller Canfield on

The year 2020 witnessed a record level of $2.78 billion in corporate fines and penalties from enforcement of the Foreign Corrupt Practices Act (FCPA) by the U.S. Department of Justice (DOJ) and the U.S. Securities and...more

Jones Day

FCPA 2020 Year in Review

Jones Day on

In 2020, the biggest Foreign Corrupt Practices Act (“FCPA”) headline was the record-shattering global anticorruption enforcement fines and penalties collected by foreign regulators in actions involving a coordinated FCPA...more

K&L Gates LLP

Voluntary Disclosure - Special Edition - A Debrief on the 37th International Conference on the Foreign Corrupt Practices Act

K&L Gates LLP on

White collar practitioners Neil Smith, William Semins, Nicole Stockey, and David Peet discuss their key takeaways from this year’s 37th International Conference on the Foreign Corrupt Practices Act....more

White & Case LLP

DOJ Global Corruption Efforts Beyond the FCPA

White & Case LLP on

Although courts have reined in the application of the Foreign Corrupt Practices Act (FCPA) anti-bribery provisions in the past two years, the US Department of Justice (DOJ) shows no sign of scaling back its global...more

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