News & Analysis as of

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

Baker Donelson

DOJ Dismisses FCPA Charges Against Former Cognizant Executives Following New Policy

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On April 2, 2025, the U.S. Department of Justice (DOJ) moved to dismiss the Foreign Corrupt Practices Act (FCPA) case against former Cognizant Technology Solutions Corp. executives Gordon Coburn and Steven Schwartz, United...more

A&O Shearman

Criminal Case Against Former Executives Of Technology Company Dismissed

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On April 2, 2025, the Department of Justice moved to dismiss with prejudice its Foreign Corrupt Practices Act (“FCPA”) case against two former executives of a technology solutions company (“Company”). The executives were...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for February 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

Zuckerman Spaeder LLP

The False Claims Act Could Become the New “It” Statute in an Uncertain Enforcement Landscape

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Uncertainty was a prominent theme at last week’s ABA White Collar Crime Institute. The Trump administration has issued a series of directives that seem to shift and narrow the scope of (if not entirely abandon) a host of...more

ArentFox Schiff

Predicting the Unpredictable: DOJ’s Enforcement Priorities From the ABA’s 40th White Collar Crime Institute

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ArentFox Schiff attorneys William Ziegelmueller and Kaitlin Klamann attended the American Bar Association’s (ABA) 40th White Collar Crime Institute (WCCI) March 5-7, 2025, in Miami, Florida. In the absence of representatives...more

Vedder Price

Government Agencies to Continue Pursuing Core Enforcement Initiatives and Other Highlights from the ABA 40th Annual National...

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The American Bar Association held its 40th Annual National Institute on White Collar Crime conference on March 5, 6, and 7, 2025, in Miami, Florida. The conference featured robust panel discussions with the federal and state...more

ArentFox Schiff

White Collar and Enforcement Outlook 2025

ArentFox Schiff on

With 2025 underway, the ArentFox Schiff White Collar team highlights the US Department of Justice’s (DOJ) new enforcement priorities and two cases pending before the US Supreme Court that could have sweeping implications for...more

A&O Shearman

US Attorney For The District of New Jersey Reverses Course And Requests Adjournment For Foreign Bribery Case Against Tech...

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On March 4, 2025, one day before a trial against former tech executives for alleged foreign bribery charges was set to commence, the United States Attorney for the District of New Jersey requested 180-day adjournment. The...more

Whiteford

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

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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

Mayer Brown

US DOJ Outlines New Enforcement Priorities for Corporations and Individuals

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On Wednesday, February 5, 2025, the newly confirmed Attorney General (AG) Pam Bondi issued fourteen memoranda to all Department of Justice (DOJ or the “Department”) employees regarding a wide range of new policies and...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

Jenner & Block

Client Alert: The Trump Administration Calls for a Pause on New FCPA Enforcement, but Don’t Abandon Compliance Programs Just Yet

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In an executive order issued on February 10, 2025 (Executive Order), and a memorandum issued by Attorney General Pam Bondi regarding cartels and transnational criminal organizations on February 5, 2025 (Cartel Memo), the...more

McCarter & English, LLP

Trump Administration Shifts DOJ’s Approach to FCPA Enforcement

On February 10, 2025, President Trump signed an Executive Order (EO) directing Attorney General Pam Bondi to halt ongoing enforcement by the Department of Justice (DOJ) in all active prosecutions brought pursuant to the...more

ArentFox Schiff

Investigations Newsletter: President Trump Puts a “Pause” on FCPA Enforcement

ArentFox Schiff on

President Trump Puts a “Pause” on FCPA Enforcement - On Monday, President Donald Trump signed an executive order (EO) pausing the enforcement of the Foreign Corrupt Practices Act (FCPA). According to the EO, the pause will...more

K&L Gates LLP

President Trump Orders FCPA Freeze; DOJ Announces Major Policy Realignment De-Emphasizing Corporate Investigations and Enforcement

K&L Gates LLP on

The much-heralded end to prosecutions brought pursuant to the Foreign Corrupt Practices Act (FCPA) never materialized during the first Donald Trump administration, but Trump 2.0 has the potential to bring major change to the...more

Alston & Bird

Pause and Effect: The Trump Administration Takes Aim at the FCPA

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Our White Collar, Government & Internal Investigations Team examines the impact of President Trump’s Executive Order pausing enforcement of the Foreign Corrupt Practices Act and identifies some key considerations and...more

McGuireWoods LLP

Practical Tips for Companies Following President Trump’s Pause on FCPA Enforcement

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Since the President signed the February 10, 2025 Executive Order (Order) pausing enforcement of the Foreign Corrupt Practices Act (FCPA) (Client Alert: President Trump issues Executive Order “Pausing Foreign Corrupt Practices...more

Cozen O'Connor

U.S. Dials Back Implementation of Foreign Corrupt Practices Act

Cozen O'Connor on

On February 10, 2025, President Trump signed an executive order instructing the Department of Justice (DOJ) and Attorney General (AG) Pamela Bondi to “cease initiation of any new [Foreign Corrupt Practices Act (FCPA) (15...more

Kramer Levin Naftalis & Frankel LLP

President Trump Signs Executive Order Pausing Enforcement Under the FCPA; Attorney General Bondi Issues 14 Memoranda Realigning...

On Feb. 10, President Donald Trump issued an executive order pausing enforcement under the Foreign Corrupt Practices Act (FCPA or the Act) for a period of at least 180 days and up to 360 days. The order directs Attorney...more

Alston & Bird

Trump Administration Halts New FCPA Enforcement, Will Review Open Investigations

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In a move that sent shockwaves through the world of white collar corporate defense, President Trump has issued an Executive Order instructing the Attorney General to pause new FCPA enforcement subject to review existing FCPA...more

Skadden, Arps, Slate, Meagher & Flom LLP

Anti-Bribery and Corruption Risks Remain Despite FCPA Enforcement Pause

On February 10, 2025, President Donald Trump signed an executive order directing the U.S. attorney general, Pam Bondi, to pause Foreign Corrupt Practices Act (FCPA) actions for 180 days until she issues revised FCPA...more

White & Case LLP

FCPA Freeze and Refocus: Is Enforcement Becoming a Tool to Promote U.S. Economic, Foreign Policy and National Security Interests?

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On February 10, 2025, President Trump signed an executive order instructing the Attorney General of the United States to pause enforcement of the Foreign Corrupt Practices Act ("FCPA") and to issue updated guidelines for...more

American Conference Institute (ACI)

An FCPA Enforcement Pause Does Not Pause Anti-Corruption Compliance

U.S. Foreign Corrupt Practices Act (FCPA) enforcement activity may be at a temporary standstill, but that should not mean much for the day-to-day operations of global anti-corruption compliance programs. If the Department of...more

Benesch

President Trump “Pauses” FCPA Enforcement: What This Means for Legal & Compliance Departments

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On February 10, 2025, President Trump issued an Executive Order entitled Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security. The executive order comes just days after the...more

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