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Foreign Corrupt Practices Act (FCPA) Enforcement Actions Criminal Prosecution

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

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

ArentFox Schiff

White Collar and Enforcement Outlook 2025

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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

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

Womble Bond Dickinson

Compliance Still Matters: The Future of FCPA Enforcement

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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

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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

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

K&L Gates LLP

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

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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

Ballard Spahr LLP

Attorney General Bondi Overhauls Justice Priorities

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The new administration has signaled that the Department of Justice (“DOJ”) will significantly shift its approach to criminal corporate enforcement. Specifically, on February 5, 2025, newly-confirmed United States Attorney...more

Seward & Kissel LLP

Pausing Bribery Prosecutions: What Companies Need to Know

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Last week President Trump signed an Executive Order pausing enforcement of the nation’s most robust anti-bribery statute, the Foreign Corrupt Practices Act (“FCPA”). The EO seeks a complete overhaul of the FCPA enforcement...more

Vinson & Elkins LLP

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

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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

Cozen O'Connor

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

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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

Hogan Lovells

Criminal FCPA enforcement paused. Now what?

Hogan Lovells on

On February 10, 2025, President Trump ordered the U.S. Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) and issue new enforcement guidelines that take into consideration U.S....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

Ropes & Gray LLP

Enforcement under the Trump Administration: Reports of the FCPA’s Death are Exaggerated

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On February 10, 2025, President Trump issued an executive order (the “EO”) directing the U.S. Department of Justice (“DOJ”) to pause new Foreign Corrupt Practices Act (“FCPA”) investigations and enforcement actions for 180...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

Sheppard Mullin Richter & Hampton LLP

Attorney General Bondi’s Day One Orders for DOJ

Shortly after her confirmation, and just after her swearing-in by Associate Justice Clarence Thomas, U.S. Attorney General Pamela Bondi issued fourteen memoranda that seek to reform the Department of Justice by rescinding...more

A&O Shearman

Federal Departments And Regulatory Agencies Move Quickly To Reorganize Structure And Policy Goals Following Introduction Of New...

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Department of Justice - One day after her confirmation on February 4, 2025, Attorney General Pam Bondi issued two Memos addressed to the entire Department of Justice (DOJ), which curtailed enforcement under the Foreign...more

Faegre Drinker Biddle & Reath LLP

The Department of Justice’s Policy Changes — Key Takeaways for the Business Community

Over the past few days, the Department of Justice (DOJ) has issued several significant policy memos that reshape the landscape for corporate legal risk, particularly for multinational corporations engaged in international...more

Snell & Wilmer

New Memoranda Issued by Attorney General Bondi: Department of Justice Corporate Enforcement Topics

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Pam Bondi was sworn into office as the United States Attorney General on February 5, 2025, and immediately issued a bevy of memoranda advancing the Trump Administration’s priorities. The memorandum entitled General Policy...more

ArentFox Schiff

Three Actions to Take in Response to the DOJ’s New Corporate Enforcement Priorities

ArentFox Schiff on

Last week, Attorney General Pamela Bondi issued 14 memoranda outlining new enforcement priorities at the US Department of Justice (DOJ). Notably, DOJ resources will shift away from the Foreign Corrupt Practices Act (FCPA) and...more

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