News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Enforcement Actions Government Investigations

Carlton Fields

President Trump Issues Executive Order Pausing Enforcement of FCPA: A Sea Change Moment for DOJ and SEC

Carlton Fields on

On February 10, 2025, President Trump issued Executive Order 14209, titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security,” with the stated purpose of eliminating...more

Latham & Watkins LLP

President Trump Issues Executive Order Pausing Foreign Corrupt Practices Act Enforcement at DOJ

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The order pauses new FCPA criminal cases, directs review of existing cases, and leaves open several questions, including implications for specific business sectors and civil enforcement....more

Vinson & Elkins LLP

New Year and New Administration: DOJ Races to Clear Its FCPA Docket Before the Trump Administration Begins

Vinson & Elkins LLP on

As we approach Inauguration Day on January 20, 2025, one question among anticorruption practitioners is how the Trump administration will handle enforcement of the Foreign Corrupt Practices Act (“FCPA”). In the meantime, we...more

StoneTurn

Meeting DOJ and SEC Post-Settlement Obligations: A Practical Guide

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No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more

Butler Snow LLP

Company Cooperation Leads to Criminal Discovery

Butler Snow LLP on

When a company discovers that a crime may have been committed by individuals within the company, or is alerted by the government of that possibility, the company will often hire an outside law firm to conduct an internal...more

BCLP

Fallout from the Glencore resolutions & lessons learned

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On 24 May 2022, Glencore International AG announced a series of coordinated resolutions with various international enforcements agencies including the Department of Justice (”DOJ”), the Commodity Futures Trading Commission...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 5 - Doing Business Overseas: The Foreign Corrupt Practices Act

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Dive into the history and current state of the Foreign Corrupt Practices Act with Joseph DeMaria, a Fox Rothschild partner and former federal prosecutor, and Matthew Adams, Co-Chair of the White-Collar Criminal Defense &...more

WilmerHale

2021 Global Anti-Bribery Year-in-Review

WilmerHale on

In 2021, the number of publicly resolved Foreign Corrupt Practices Act (FCPA) cases was relatively low compared with previous years, but there were numerous interesting developments, and enforcement activity going forward...more

The Volkov Law Group

2022 FCPA Predictions

The Volkov Law Group on

This was a strange year.  Not just because of the continuing pandemic and economic disruption. The Biden Administration took over after an unusual and delayed transition. The apparatus of government was slow to transition....more

Eversheds Sutherland (US) LLP

Enforcement appears as messages disappear: The perils of personal and ephemeral messaging

On December 17, 2021, a financial institution agreed to pay $200 million in fines to the Securities and Exchange Commission and Commodities Futures Trading Commission for allowing employees to discuss business on their...more

Jones Day

DOJ Announces Policy Changes and Additional Resources Focused on White-Collar Enforcement

Jones Day on

Introduction In the first 10 months of the Biden administration, senior DOJ officials have signaled a renewed focus on corporate criminal and civil enforcement against companies and individuals.  ...more

WilmerHale

Foreign Corrupt Practices Act Alert - Global Anti-Bribery Year-in-Review: 2019 Developments and Predictions

WilmerHale on

Enforcement activity reached new heights in 2019. The year saw the two largest corporate resolutions in the history of the FCPA, corporate penalties paid to US enforcement agencies topped last year’s record levels, and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - September 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more

The Volkov Law Group

Juniper Networks Settles FCPA Violations with SEC for $11.7 Million

The Volkov Law Group on

Juniper Networks agreed to pay the SEC $11.7 million to settle FCPA violations for conduct occurring in Russia and China. Under the settlement, Juniper Networks agreed to disgorgement of $4 million, a $6.5 million civil...more

Thomas Fox - Compliance Evangelist

TechnipFMC FCPA Enforcement Action-Lessons Learned

We continue our exploration of the TechnipFMC Foreign Corrupt Practices Act (FCPA) enforcement action by considering the actions taken by the company (or both separately before their merger) in response to their FCPA...more

Hogan Lovells

U.S. and Brazilian Authorities Reportedly Cooperating in Investigation of Alleged Bribery and Price Fixing Related to Medical...

Hogan Lovells on

In a May 17, 2019 press report that has been widely distributed in Brazil and the United States, Brazilian Federal Prosecutor Marisa Ferrari confirmed that the U.S. Federal Bureau of Investigation (FBI), the U.S. Department...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Amends Corporate Enforcement Policy on Companies’ Use of Electronic Messaging Apps

On March 8, 2019, the U.S. Department of Justice announced an important change to its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy concerning one of the conditions — “appropriate retention of business...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - January 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including DOJ guidance on the use of corporate monitors in criminal...more

Kramer Levin Naftalis & Frankel LLP

DOJ Announces More Lenient Corporate Cooperation Policy

In a speech delivered on Thursday, Nov. 29, 2018, Deputy Attorney General Rod Rosenstein described important changes to DOJ policies for awarding cooperation credit in corporate investigations. These changes have been...more

Troutman Pepper Locke

Revised DOJ Corporate Cooperation Policy Supports More Efficient Resolutions

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On November 29, Deputy Attorney General Rod Rosenstein announced revisions to the Department of Justice’s policy on corporate cooperation in government investigations, which may make it easier for companies under...more

Farella Braun + Martel LLP

Battling Government Investigations Series – Cooperation and Voluntary Disclosure

It always comes when you least expect it – a government inquiry to investigate your business. While it may instill a sense of panic, there are steps you can take to make sure you’re in the best position possible when the...more

Cohen & Gresser LLP

Managing the Risks of Cross-Border Investigations for Israeli Businesses

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Enforcement Efforts Are Increasingly International - White collar investigations and prosecutions, notably those initiated by American authorities, have become increasingly international, reaching far beyond the borders of...more

Thomas Fox - Compliance Evangelist

Responding to Investigative Findings

Most companies understand a the need for an investigative protocol or bringing in experienced investigative counsel should a substantive Foreign Corrupt Practices Act (FCPA) allegation arise. However what is not as well known...more

The Volkov Law Group

DOJ Continues Run on Individual FCPA Criminal Prosecutions

The Volkov Law Group on

The Department of Justice announced criminal FCPA charges against two individuals in connection with bribery payments to foreign officials in Chad and Uganda. The Justice Department’s announcement occurred on the heels of...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross Border Investigations Update - July 2017

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases and enforcement trends, including the new Criminal Finances Act 2017, increased regulatory scrutiny of Chinese companies...more

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