News & Analysis as of

Foreign Corrupt Practices Act (FCPA) National Security Criminal Prosecution

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

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

Holland & Knight LLP

President Trump Issues Executive Order to Halt FCPA Enforcement

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President Donald Trump signed an executive order (EO) pausing all future investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA) for at least 180 days, along with directing the U.S. attorney...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

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

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

White & Case LLP

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

White & Case LLP on

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

Hogan Lovells

Criminal FCPA enforcement paused. Now what?

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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)

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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

Ropes & Gray LLP

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

Ropes & Gray LLP on

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

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

Nossaman LLP

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

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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

The Volkov Law Group

The Sanctions Year in Review: DOJ takes First Steps to Enforce “The New FCPA” While OFAC’s Enforcement Actions Decline

The Volkov Law Group on

Enforcement and compliance prognosticators (like myself) continued to push DOJ’s promise to transform sanctions enforcement into the era of “the new FCPA.” While DOJ’s promise to bring about an aggressive corporate...more

The Volkov Law Group

DOJ’s Balancing Act — Incentives to Cooperate and Deterrence (Part III of III)

The Volkov Law Group on

While DOJ did not have an overwhelming FCPA enforcement year, DOJ has devoted significant energy to tweaking its enforcement and compliance policies.  These measures were believed to coincide with a number of significant...more

The Volkov Law Group

Corporate Crime and National Security – The Confluence of Prosecution and Foreign Policy (Part I of III)

The Volkov Law Group on

To restate the obvious – DOJ has prioritized prosecution of national security crimes.  For the business world, every company touches the international economy.  Even a domestic company might sell products or services outside...more

McDermott Will & Emery

[Webinar] 2022 Enforcement Outlook Series - Foreign Corrupt Practices Act/Anti-Corruption - March 8th, 12:00 pm - 1:00 pm EST

McDermott Will & Emery on

As expected when a new administration takes office, 2021 saw a surge in white-collar enforcement activity. There was a 12% increase in white-collar prosecutions during US President Joe Biden’s first year in office, and that...more

Goodwin

2021 Year in Review: FCPA

Goodwin on

A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

Jones Day

FCPA 2021 Year In Review

Jones Day on

The Biden administration took office in January 2021, announcing aggressive and sweeping anticorruption initiatives to tackle corruption around the world, labeling corruption a national security priority, and signaling a...more

Dechert LLP

Tensions Rise Between China and the United States: Intellectual Property Prosecutions Just the Tip of the Iceberg

Dechert LLP on

Amid escalating tensions between the United States and China over the last few years, the United States Department of Justice (“DOJ”) has formally prioritized criminal prosecutions of Chinese nationals and companies, and...more

A&O Shearman

Airbus Agrees Record-Breaking €3.6 Billion Settlement to Avoid Prosecution

A&O Shearman on

On 31 January 2020, Airbus SE (Airbus) reached final agreements with the French Parquet National Financier (PNF), the U.K.’s Serious Fraud Office (SFO) and the U.S. Department of Justice (DoJ) in order to resolve...more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 6 – The Investigation, the Remediation and Final Thoughts

Over the past several blog posts, I have been exploring the Airbus SE (Airbus) international anti-corruption settlement in some depth. One of the questions I have had and hopefully raised for readers is not why the overall...more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 5 – The UK Judgment on the DPA

Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more

The Volkov Law Group

Airbus Systemic Bribery and Export Violations: Understanding How a Company’s Compliance Program and Culture Failed (Part IV of IV)

The Volkov Law Group on

When reviewing a major enforcement case, I always ask two basic questions: What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance?...more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 4 – Alphabet Agency Violations (Export Control and Export Finance)

Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more

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