News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Trump Administration

Vinson & Elkins LLP

Focus, Fairness, & Efficiency: DOJ White Collar Policy Shifts Signal Recalibration, But Not Revolution in Enforcement

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On May 12, 2025, the Criminal Division of the U.S. Department of Justice (“DOJ” or the “Department”) issued a series of significant policy changes outlining the Trump administration’s new approach to white-collar enforcement....more

Foley Hoag LLP

DOJ Announces New Priorities in White-Collar Criminal Enforcement: Targeting Waste, Fraud, and Abuse and Protecting American...

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The U.S. Department of Justice’s ("DOJ") Criminal Division recently issued a memorandum outlining a shift in the DOJ’s priorities and policies for prosecuting white-collar crime (the “Memorandum”). Issued by the Head of the...more

DarrowEverett LLP

The DOJ’s New White-Collar Agenda: Implications for Businesses

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On May 12, 2025, the Department of Justice (the “DOJ”) released its criminal—and, more specifically, white collar crime enforcement—initiatives under the current administration. This is typical each time new leadership...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for April 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

Herbert Smith Freehills Kramer

DOJ Announces White-Collar Enforcement Priorities and Revised Corporate Enforcement & Voluntary Self-Disclosure Policy

On May 12, 2025, the Department of Justice (“DOJ” or the “Department”) issued a revised Corporate Enforcement and Voluntary Self-Disclosure Policy (Revised CEP). Matthew R. Galeotti, chief of the Criminal Division of the DOJ,...more

McCarter & English, LLP

DOJ Criminal Division Announces White Collar Enforcement Priorities and Policy Changes to White Collar Investigations

Earlier this week, the US Department of Justice (DOJ) released a new white collar enforcement plan (Enforcement Plan) outlining changes to the Criminal Division’s white collar enforcement priorities to align more closely with...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ White Collar Enforcement Plan Continues To Present Risks for Non-US Companies

Matthew Galeotti’s recent memorandum as head of the Department of Justice’s (DOJ’s) Criminal Division echoes the Trump administration’s “America First” priorities. It directs the Criminal Division to “strike an appropriate...more

The Volkov Law Group

This is Not the Time to Retreat on Compliance

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Call me an optimist — it is a much better alternative than being a pessimist or a “realist” with a pessimistic bent. So, let’s start by acknowledging the obvious. Businesses are operating in a volatile environment. The...more

DLA Piper

The Second Trump Administration’s First 100 days

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The first 100 days of the second Trump Administration have been marked by a flurry of Executive Orders (EOs) and policy memoranda intended to advance President Donald Trump’s “America First” agenda. In the process, these...more

Skadden, Arps, Slate, Meagher & Flom LLP

President Trump’s First 100 Days: Impacts and Projections

The first 100 days of a new administration sets the tone for policy direction and regulatory priorities. The following key takeaways from the Trump administration’s first three months highlight significant trends, shifts and...more

DLA Piper

Key Considerations for Compliance Officers Under President Trump

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The Trump Administration has ushered in massive shifts in enforcement and policy priorities. From crypto to anti-corruption measures and tariffs to technology, the new Administration has changed the compliance landscape...more

Brownstein Hyatt Farber Schreck

California Warns Foreign Bribery Can Still Lead to State Liability

California’s attorney general recently reminded businesses that regardless of what the Trump administration does, businesses can still be responsible for violations of state law. In a recently issued legal advisory, state...more

Jenner & Block

Jenner & Block Japan Newsletter - April 2025

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Welcome to the April 2025 edition of the Jenner & Block Japan Newsletter, a publication containing updates about legal developments in the United States that may be noteworthy to our clients and other leaders in the Japanese...more

Miles & Stockbridge P.C.

Despite Reduced Enforcement Risks, Businesses Should Invest in Corporate Compliance

Some early actions by the Trump administration have led corporate legal departments to question the extent to which they need to invest in ethics and compliance at this time, based on a perceived reduction in enforcement...more

NAVEX

California Reminds Businesses Bribery is Illegal – Why Other States Should Follow Suit

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On February 10, 2025, President Trump issued an  executive order pausing federal enforcement over the U.S. Foreign Corrupt Practices Act by ordering the U.S. Attorney General to “cease initiation of any new FCPA...more

Thomas Fox - Compliance Evangelist

Upping Your Game: Episode 1 – Meeting Hui Chen’s Challenge

In February, the Trump Administration suspended investigations under and enforcement of the FCPA. Many compliance professionals have since wondered what this will mean for corporate compliance programs going forward. Hui Chen...more

Husch Blackwell LLP

State Attorneys General May Step Up Foreign Anti-Corruption Enforcement Efforts Following Federal Enforcement Pause

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For decades Foreign Corrupt Practices Act (FCPA) enforcement has been largely considered a federal matter, with the U.S. Department of Justice (DOJ) enforcing the statute’s criminal provisions.[1] Enacted in 1977, FCPA...more

King & Spalding

Anti-Bribery and Anti-Corruption Enforcement in the U.S., UK, and Europe post-FCPA Pause

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We have previously written about the impact of the pause in enforcement of the FCPA implemented by the Trump Administration on non-American companies.1 Although the 180-day review period the Executive Order provided to the...more

Goodwin

How the New Administration Is Reshaping Trade

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Today my colleagues and I will discuss recent developments in the US trade regulatory space. We’re almost 100 days into the new administration, which stepped into a dynamic US trade regulatory environment, including new...more

Foley Hoag LLP - State AG Insights

Will State AGs Fill the Gap in FCPA Enforcement?

Since the start of President Trump’s second administration, some State Attorneys General (AGs) have actively responded to executive orders and policy directives, including by initiating legal challenges in federal courts. Now...more

White & Case LLP

A Vested Interest in Honest Business: California Attorney General Reminds Businesses that FCPA Violations Remain Actionable under...

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On April 2, 2025, California Attorney General Rob Bonta issued a Legal Advisory reminding businesses operating in California that foreign bribery remains illegal under California law and that violations of the US Foreign...more

Wilson Sonsini Goodrich & Rosati

California AG Warns Companies That FCPA Violations Are Still Enforceable Notwithstanding Federal Pause

On April 2, 2025, California Attorney General Rob Bonta issued a press release and legal advisory reminding businesses operating in California that violations of the Foreign Corrupt Practices Act (FCPA) are still actionable...more

Miller Nash LLP

FCPA Update: Enforcement Landscape Shifts Under New Executive Order

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As a follow-up to our previous article, "To Tariff, or Not to Tariff?", President Trump issued an Executive Order on February 10, 2025, directing the Attorney General to review the current guidelines and enforcement policies...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for March 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

K2 Integrity

[Webinar] FCPA & FEPA versus the Middle East – What can we expect in the coming year? - April 30th, 9:00 am ET

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Join our panel of experts for a one-hour session where they will discuss the impact of the halt on FCPA and FEPA enforcement by the Trump administration and what it means for the Middle East in terms of investigations and...more

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