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Foreign Corrupt Practices Act (FCPA) Criminal Prosecution Corruption

WilmerHale

UK, French, and Swiss Enforcement Authorities Announce New Alliance

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Anti-bribery and corruption agencies in the UK, France and Switzerland today announced a shared commitment to tackling international bribery and corruption, by way of a new taskforce intended to strengthen collaboration....more

Whiteford

Client Alert: Attorney General Bondi Changes Direction on FCPA and FARA Prosecutions

Whiteford on

On her first day in office, Attorney General Pam Bondi announced several changes to the standards governing the exercise of prosecutorial discretion, charging decisions, plea negotiations and sentencing recommendations. Two...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for January 2025

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

Vedder Price

Changed Focus of FCPA Actions Under Trump Executive Order

Vedder Price on

On February 5, 2025, newly appointed U.S. Attorney General Pam Bondi issued a memorandum titled “Total Elimination of Cartels and Transnational Criminal Organizations” (the February 5 Memorandum), which outlined a broad...more

Vinson & Elkins LLP

Future of FCPA Enforcement Uncertain (For Now) as New Administration Revamps the Law Enforcement Toolkit

Vinson & Elkins LLP on

Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more

The Volkov Law Group

New FCPA Guidance — What to Expect (Part IV of V)

The Volkov Law Group on

As we continue through the maze of Executive Orders and new Guidance, which is expected in 180 days, the questions surrounding FCPA enforcement are swirling.  In some respects, we have had a preview.  It is hard to know what...more

Lowenstein Sandler LLP

Long Live the FCPA?

Lowenstein Sandler LLP on

The Trump administration has taken significant action this week to overhaul the executive branch’s long-standing policy toward the prosecution of white collar offenses. First, a memo issued by newly confirmed U.S. Attorney...more

Holland & Knight LLP

A Game-Changer Relating to FCPA Enforcement

Holland & Knight LLP on

U.S. Attorney General (AG) Pam Bondi on her first day in office – Feb. 5, 2025 – sent several memos to all employees of the U.S. Department of Justice (DOJ) laying out top priorities. In one memo, the DOJ instructs its...more

Akin Gump Strauss Hauer & Feld LLP

Analyzing the Attorney General’s FCPA Enforcement Shift

UPDATE: President Signs Executive Order Directing DOJ to Pause All FCPA Enforcement for 180 Days - On February 10, 2025, President Trump issued an Executive Order directing the U.S. Department of Justice (DOJ) to pause all...more

Womble Bond Dickinson

DOJ Narrows FCPA Enforcement Focus

Womble Bond Dickinson on

Attorney General (AG) Pam Bondi has issued a directive that both: (1) effectively shifts the DOJ’s FCPA enforcement focus towards those cases related to foreign bribery involving cartels and transnational criminal...more

Nossaman LLP

Attorney General Walks Back FCPA to Focus on “Total Elimination of International Drug Cartels”

Nossaman LLP on

The proposed expansion of the Foreign Agent Registration Act (FARA) further into private commercial activity published in the Federal Register just over a month ago may be halted due to one of the first directives issued by...more

Foley Hoag LLP - White Collar Law &...

AG Bondi Overhauls FCPA Enforcement in Day 1 Memo

On February 5, 2025, on her first day in office, U.S. Attorney General Pam Bondi issued fourteen memos outlining new policies for the U.S. Department of Justice (“DOJ”) in a broad range of enforcement arenas. Among these Day...more

Morgan Lewis

Newly Confirmed AG Pam Bondi Issues Directive Limiting Scope of FCPA Enforcement

Morgan Lewis on

Newly Appointed US Attorney General Pam Bondi issued a directive shifting the focus of Foreign Corrupt Practices Act investigations and cases away from those that do not involve criminal operations of cartels and...more

The Volkov Law Group

FCPA 2024 Enforcement — Bribery Schemes and Compliance Reminders (Part II of III)

The Volkov Law Group on

Criminals can be creative — that is a true statement but essentially FCPA criminals have to embrace a variety of well-established techniques to accomplish a straight-forward goal — steal money from the company to funnel...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments: 2024 Year in Review

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this special edition of our award-winning monthly Top 10 International Anti-Corruption Developments newsletter summarizes the most...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2024

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

The Volkov Law Group

DOJ and SEC Close 2024 with FCPA Enforcement Action Against AAR Corp; DOJ and SEC Announces Resolution with Deepak Sharma, CEO of...

The Volkov Law Group on

The Justice Department and the SEC finished 2024 with a coordinated resolution of criminal and civil FCPA charges against AAR Corporation, an Illinois-based provider of aviation products and services. In addition, DOJ...more

The Volkov Law Group

McKinsey Company's Bribery Scheme - A Familiar Pattern in South Africa (Part II of III)

The Volkov Law Group on

The McKinsey FCPA case follows several other significant cases involving South Africa.  ABB and SAP resolved FCPA cases involving bribes in South Africa; on the SEC front, Gartner resolved a bribery case involving South...more

The Volkov Law Group

Episode 349 -- Review of the BIT Mining FCPA Settlement

The Volkov Law Group on

What happens when a Chief Executive Officer becomes the architect of a global bribery scheme? In this episode of Corruption, Crime, and Compliance, Michael Volkov delivers an in-depth analysis of the BIT Mining FCPA case —...more

The Volkov Law Group

Lessons Learned from the Telefónica FCPA Settlement (Part III of III)

The Volkov Law Group on

The Justice Department’s record of FCPA enforcement in 2024 has been disappointing.  With all of the hoopla and pronouncements surrounding the global war against corruption, DOJ suggested that enforcement in 2023 and 2024...more

Thomas Fox - Compliance Evangelist

Lessons on Ongoing Monitoring and Continuous Improvement from Star Trek: Spectre of the Gun

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

The Volkov Law Group

Lessons-Learned from the Trafigura FCPA Settlement (Part III of III)

The Volkov Law Group on

The Justice Department is rightly trumpeting its successful sweep of the commodities trading industry.  DOJ’s success is reflected in its six separate corporate resolutions and 20 individual convictions, resulting in over...more

The Volkov Law Group

Trafigura’s Bribery Scheme: Clandestine Meetings, 3rd Parties and Shell Companies (Part II of III)

The Volkov Law Group on

Trafigura’s bribery scheme resembles the same schemes implemented by its significant competitors — Vitol, Glencore, Gunvor.  At the core of the conduct, Petrobras and Brazilian government officials collected bribes in...more

The Volkov Law Group

Trafigura Joins the FCPA Enforcement Club: Pleads Guilty and Pays Over $126 Million for Bribery Violations in Brazil (Part I of...

The Volkov Law Group on

On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry.  Trafigura joined the list...more

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action – Part 4 – Lessons Learned

We conclude our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary operations in...more

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