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Foreign Corrupt Practices Act (FCPA) White Collar Crimes Foreign Policy

K&L Gates LLP

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

K&L Gates LLP on

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

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

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

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – September 2024

Bass, Berry & Sims PLC on

What happened? On September 10, the SEC announced that John Deere agreed to pay almost $10 million to resolve allegations it had violated the FCPA. The SEC alleged that Wirtgen Thailand, an indirect subsidiary of John Deere,...more

The Volkov Law Group

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

The Volkov Law Group on

Sorry to start a four-part series with a reference to music from our long-ago past.  The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks?  Well,...more

The Volkov Law Group

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

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If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm.  However, that is not the corporate reality.  Even after several companies are the...more

The Volkov Law Group

2023 Sanctions Year in Review and Predictions

The Volkov Law Group on

As always, I tend to repeat myself.  However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals.  DOJ has...more

The Volkov Law Group

3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations

The Volkov Law Group on

The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more

The Volkov Law Group

Sanctions Enforcement: “The New FCPA”

The Volkov Law Group on

Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions.  The dye is cast, so here we go. ...more

Torres Trade Law, PLLC

Trade Enforcement Digest - January 2022

Torres Trade Law, PLLC on

Civil and criminal penalties levied against U.S. companies for trade violations are just the beginning of the potential unforeseen costs of doing business in the global marketplace. What cannot be quantified are the countless...more

Kramer Levin Naftalis & Frankel LLP

Biden Administration Issues Directive for Revitalized Strategies to Combat Corruption and Financial Crime, Signaling Increased...

On June 3, 2021, President Biden issued the first National Security Study Memorandum of his presidency, in which he declared fighting corruption “a core United States national security interest.” The Memorandum sets out the...more

The Volkov Law Group

DOJ Announces Voluntary Disclosure Program for Criminal Export and Sanctions Violations

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The Justice Department is often criticized for its lack of transparency.  But when it comes to policy changes or initiatives, DOJ is more than transparent – DOJ always tells the public what it plans to do and then does it....more

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