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Foreign Corrupt Practices Act (FCPA) Trump Administration Corporate Misconduct

Wiley Rein LLP

DOJ’s Approach to White Collar Enforcement: Target Those Who Harm U.S. Interests While Minimizing Collateral Damage

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The U.S. Department of Justice (DOJ) recently announced Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA). The June 9 memorandum from Deputy Attorney General Todd Blanche instructs...more

Nossaman LLP

DOJ Issues New FCPA Enforcement Guidelines

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New factors for investigating and enforcing the Foreign Corrupt Practices Act were recently released by head of the Criminal Division of the U.S. Department of Justice (DOJ) in, “Guidelines for Investigations and Enforcement...more

Bracewell LLP

DOJ’s New FCPA Investigations and Enforcement Guidelines: How Organizations Need to Respond

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The Deputy Attorney General of the U.S. Department of Justice Office recently issued new guidelines for investigations and enforcement actions of the Foreign Corrupt Practices Act. (FCPA). These new guidelines come as a first...more

Ballard Spahr LLP

Focused FCPA Enforcement: Emphasizing Security and Strategic Interests

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On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the DAG memorandum) updating the Department of Justice’s (DOJ) enforcement guidelines for the Foreign Corrupt Practices Act (FCPA) in accordance with...more

Ropes & Gray LLP

DOJ’s New FCPA Playbook: “Time To Get To Work”

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On June 9, 2025, the U.S. Department of Justice (“DOJ” or the “Department”) issued the highly anticipated guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (“FCPA”) (“FCPA Guidelines”),...more

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

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

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

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

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

Carlton Fields

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

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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

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

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

Paul Hastings LLP

Keep Calm and Carry On: Thoughts on Recent Orders on FCPA Enforcement

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What in the world is happening with enforcement of the Foreign Corrupt Practices Act (FCPA)? And what does the recent executive order (EO) and Department of Justice (DOJ) guidance mean for U.S. and global companies? Our view...more

Lowenstein Sandler LLP

Long Live the FCPA?

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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

Morrison & Foerster LLP

FCPA Enforcement Under the Second Trump Administration

Since its enactment in 1977, the FCPA has been the primary legal mechanism in the United States for preventing and punishing corrupt business practices around the world. At a high-level, the FCPA applies to both domestic and...more

WilmerHale

FCPA Year-in-Review: 2024 Developments and Predictions for 2025

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Foreign Corrupt Practices Act (FCPA) enforcement activity increased overall in 2024, with a notable uptick in Department of Justice (DOJ) enforcement actions compared to 2023, despite a decrease in public Securities and...more

The Volkov Law Group

FCPA Predictions: Don’t Expect Much to Change

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In 2017, when President Trump first took office, big changes were expected in FCPA enforcement.  Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA.  He was not a big fan of the law and...more

Vinson & Elkins LLP

Holiday Jeers: How The Grinch at DOJ May Make It Harder for Companies to Stay on the Nice List This Christmas

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With the holiday season upon us, companies waiting for a nice surprise this Christmas are more likely to find a lump of coal in their stocking. In a series of recent announcements, Department of Justice (“DOJ”) officials have...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - November 2018

ANTICORRUPTION DEVELOPMENTS - Deputy Attorney General Rod Rosenstein Announces Pursuing Individuals Will be a “Top Priority” for Corporate Enforcement Actions - On November 29, 2018, Deputy Attorney General Rod J....more

Moore & Van Allen PLLC

Is the Trump Administration Charting a New Course Away from the Duplicative Fines of the Financial Crisis?

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Double jeopardy prevents criminal defendants from being convicted of the same crime twice. Res judicata prevents civil litigants from facing repeated claims by an overly aggressive plaintiff. Unfortunately, in the years after...more

Farella Braun + Martel LLP

FCPA in the Trump DOJ: Continuing Down the Same Path, with a Little More Heft

Next week marks the 40th anniversary of the Foreign Corrupt Practices Act – it became effective December 19, 1977. Deputy Attorney General Rod Rosenstein marked the occasion this month by providing an update on the FCPA Pilot...more

Foley & Lardner LLP

The Foreign Corrupt Practices Act and the New Trump Administration: Your Top Ten Questions Answered

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Since mid-2000s investigation of Siemens, and the resulting $800 million penalty for violations of the Foreign Corrupt Practices Act (FCPA), the FCPA has been an enforcement priority of the U.S. Government. Although a dip in...more

NAVEX

AG Jeff Sessions Left Compliance Officers with More Questions than Answers … and an Invitation

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Attorney General Jeff Sessions was a keynote speaker at the 2017 Ethics & Compliance Initiative’s Annual Conference last week. Whatever your politics are, it was important that we hear from him on his priorities for...more

Foley & Lardner LLP

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

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Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

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