News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Department of Justice (DOJ) White Collar Crimes

The Volkov Law Group

DOJ’s Fresh FCPA Enforcement Initiative — What’s New, What’s Not (Part II of II)

The Volkov Law Group on

DOJ’s new approach to FCPA enforcement presents some interesting opportunities — the headlines from the DOJ FCPA Guidance Memo will bring some significant changes but at the same time some things will not change.  Here is my...more

Jenner & Block

Client Alert: Back in Action: The Trump Administration Lifts “Pause” in Foreign Corrupt Practices Act Enforcement

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Approximately four months after President Trump imposed a pause on new Foreign Corrupt Practice Act (FCPA) investigations and enforcement actions, the US Department of Justice (DOJ) has issued new guidelines lifting that...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

Proskauer Rose LLP

DOJ Adopts Risk-Based Approach in FCPA & White-Collar Enforcement Policy Shift

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On June 9, 2025, the U.S. Department of Justice (“DOJ”) issued guidelines governing investigations and the enforcement of the Foreign Corrupt Practices Act (FCPA), following through on commitments made in President Trump’s...more

The Volkov Law Group

Justice Department Resumes FCPA Enforcement with New, Focused Guidance (Part I of II)

The Volkov Law Group on

The Justice Department has returned to the FCPA enforcement arena — in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles.  The new guidance is an...more

Troutman Pepper Locke

Trump Administration's FCPA Investigations and Enforcement Guidelines

Troutman Pepper Locke on

On June 9, Deputy Attorney General Todd Blanche released a much-anticipated update to the Trump administration’s plans for enforcement of the Foreign Corrupt Practices Act (FCPA)....more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for May 2025

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

Cooley LLP

DOJ Resumes Foreign Bribery Investigations, Focusing on ‘Vindication of US Interests’

Cooley LLP on

On June 9, 2025, the Department of Justice (DOJ) issued new guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (FCPA), following a four-month pause of new FCPA investigations per President...more

ArentFox Schiff

Investigations Newsletter: DOJ Criminal Division Head Details White-Collar Enforcement Priorities and Related Policy Revisions

ArentFox Schiff on

DOJ Criminal Division Head Details White-Collar Enforcement Priorities and Related Policy Revisions - On June 10, the head of the US Department of Justice’s (DOJ) Criminal Division, Matthew R. Galeotti, gave a speech...more

Alston & Bird

FCPA Pause, We Hardly Knew Ye: The DOJ Issues New FCPA Enforcement Guidance

Alston & Bird on

Our White Collar, Government & Internal Investigations Team analyzes new guidance from the Department of Justice that signals continued—and potentially heightened—enforcement of the Foreign Corrupt Practices Act....more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report: Recent DOJ Policy Announcements

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, Tom Fox welcomes back James Tillen and Ann Sultan, both partners at Miller & Chevalier, and takes a deep dive into four...more

Cadwalader, Wickersham & Taft LLP

The Pause is Over—the FCPA Lives On

On June 9, 2025, the U.S. Department of Justice (DOJ) announced the resumption of Foreign Corrupt Practices Act (FCPA) enforcement, ending the enforcement pause initiated by Executive Order 14209. In doing so, Deputy Attorney...more

Bass, Berry & Sims PLC

Is the “Pause” Over? DOJ Resumes FCPA Enforcement, Announces Guidelines

Bass, Berry & Sims PLC on

On June 9, Deputy Attorney General Todd Blanche issued a memorandum entitled Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (the Memo) addressed to the head of the Criminal Division of the...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

Hogan Lovells

FCPA reloaded: The DOJ “unpauses” enforcement – But is it a new level?

Hogan Lovells on

On June 9, 2025, Deputy Attorney General Todd Blanche issued revised enforcement guidelines for the Foreign Corrupt Practices Act (FCPA), officially ending the FCPA enforcement pause that Executive Order 14209 (EO) instituted...more

Husch Blackwell LLP

DOJ Poised to Reboot FCPA Investigations and Enforcement

Husch Blackwell LLP on

Issued on February 10, 2025, Executive Order 14209 (“Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security”) called on the Department of Justice (DOJ) to “review guidelines and...more

Paul Hastings LLP

New DOJ FCPA Guidelines Target Cases Linked to US Strategic Interests

Paul Hastings LLP on

On June 9, U.S. Deputy Attorney General Todd Blanche issued a memorandum entitled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA),” which establishes guidelines to ensure that FCPA...more

Perkins Coie

FCPA Is Here to Stay: DOJ Reaffirms Commitment to Enforce FCPA

Perkins Coie on

On June 9, 2025, the U.S. Department of Justice (DOJ) unveiled new guidelines for enforcing the Foreign Corrupt Practices Act (FCPA), marking a pivotal shift in how corruption cases are pursued. The guidelines seek to...more

Skadden, Arps, Slate, Meagher & Flom LLP

Deputy Attorney General Issues FCPA Guidelines Resuming Limited Enforcement

Key Points - - The U.S. Department of Justice (DOJ) will resume investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA), prioritizing, in part, FCPA actions involving cartels and transnational...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

Fenwick & West LLP

DOJ Unpauses FCPA Enforcement with New Limits

Fenwick & West LLP on

On February 10, 2025, the president signed an executive order that paused investigation and enforcement of the FCPA for a period of 180 days, required the DOJ to review any existing FCPA investigation or prosecution, and to...more

Baker Botts L.L.P.

Back from the Dead? Takeaways from US DOJ’s New Guidelines for FCPA Investigations and Enforcement

Baker Botts L.L.P. on

On June 9, 2025, the Deputy Attorney General of the United States Department of Justice issued “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (the “Memorandum”). The Memorandum...more

Womble Bond Dickinson

New FCPA Guidance By DOJ

Womble Bond Dickinson on

The Department of Justice ("DOJ") recently announced new guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (FCPA). ...more

Cozen O'Connor

DOJ Restarts Enforcement of Foreign Corrupt Practices Act, Focusing on U.S. Interests

Cozen O'Connor on

On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum titled "Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)." The memo follows a four-month review triggered by...more

ArentFox Schiff

DOJ Issues New Guidelines for FCPA Investigation and Enforcement

ArentFox Schiff on

On June 9, Deputy US Attorney General Todd Blanche issued a memorandum outlining new guidelines for the enforcement of the Foreign Corrupt Practices Act (FCPA)....more

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