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Foreign Policy Department of Justice (DOJ)

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

Mayer Brown

Heightened Enforcement Risks and Opportunities in International Trade

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On April 2, 2025, the Trump Administration imposed a sweeping new set of tariffs against imported goods as part of its efforts to remake the framework for international trade. ...more

Wiley Rein LLP

Sens. Grassley and Peters Introduce Foreign Agents Transparency Act to Enable DOJ to Require Retroactive FARA Registration

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On March 13, 2024, Senator Chuck Grassley (R-IA), Chairman of the Senate Judiciary Committee, and Senator Gary Peters (D-MI), Ranking Member of the Homeland Security and Governmental Affairs Committee, introduced the Foreign...more

Saul Ewing LLP

The Foreign Agents Registration Act: 2024 Year in Review and Outlook for 2025

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Executive Summary - We entered 2025 with the world in turmoil, a new American administration in the White House, and various global actors—friends and foes alike—still actively vying for the attention of the American public. ...more

White & Case LLP

United States Designates Eight Cartels and Transnational Criminal Organizations

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Effective February 20, 2025, the United States Designated Eight Cartels and Transnational Criminal Organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs)....more

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

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Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...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

Quarles & Brady LLP

New Tariffs Mean New Targets of the False Claims Act

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The value of goods imported to the United States in Fiscal Year 2024 was $893.15 billion, and as a result, U.S. Customs and Border Protection (“CBP”) collected $24.37 billion in duties, taxes and fees for those imports. Given...more

Vinson & Elkins LLP

Future of FCPA Enforcement Uncertain (For Now) as New Administration Revamps the Law Enforcement Toolkit

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Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more

Proskauer Rose LLP

Back to the Future: Protection of Foreign Affairs Focus for FCPA Enforcement

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Under the guise of protecting the President’s authority to conduct foreign affairs, on February 10, 2025, President Donald J. Trump signed an Executive Order pausing enforcement of the U.S. Foreign Corrupt Practices Act...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

Seward & Kissel LLP

President Trump Seeks “Maximum Pressure” on Iran Through Expansion of Sanctions Targeting Iran’s Oil Exports

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As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...more

Nelson Mullins Riley & Scarborough LLP

Bribers, Start Your Engines or Pump the Brakes?

Five Fast Reminders as Trump Pauses FCPA Enforcement - Late on February 10, 2025, President Trump issued an Executive Order (“EO”) instructing the Attorney General to pause Foreign Corrupt Practices Act (“FCPA”)...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

Skadden, Arps, Slate, Meagher & Flom LLP

Trump Orders Attorney General To Temporarily Pause FCPA Enforcement

On February 10, 2025, President Donald Trump issued an executive order directing the attorney general to pause, for a period of 180 days, new enforcement actions under the Foreign Corrupt Practices Act (FCPA). The federal...more

Jenner & Block

Client Alert: Bondi DOJ Pivots on Approach to National Security Enforcement

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On February 5, 2025, in one of her first actions as the nation’s chief law enforcement official, Attorney General Pam Bondi issued several new memoranda that significantly refocus US Department of Justice (DOJ) national...more

Katten Muchin Rosenman LLP

President Trump Pauses FCPA Enforcement

On February 10, 2025, President Donald Trump issued an Executive Order titled "Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security" (the "E.O."). The E.O was issued five days...more

Woods Rogers

Designating Cartels as Terrorists: Potential Impact on U.S. Businesses

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On his first day in office, President Trump signed an executive order (EO 14157) that sets in motion the designation of certain cartels and transnational crime gangs as terrorist organizations. The President declared a...more

BakerHostetler

Requiem for Task Force KleptoCapture: The Future of Russia Sanctions Enforcement

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On February 5, 2025, the new Attorney General announced the disbanding of Task Force KleptoCapture, which was launched in March 2022 to enforce the sweeping portfolio of sanctions against Russia. KleptoCapture was part of an...more

Snell & Wilmer

FARA's Pendulum: Shifts in Foreign Agent Regulation

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On her first day in office, Attorney General Pamela Bondi issued a memorandum signaling a significant shift in the Department of Justice’s (DOJ) approach to Foreign Agents Registration Act (FARA) enforcement. The memorandum...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

Skadden, Arps, Slate, Meagher & Flom LLP

Attorney General Announces Shift in Foreign Agents Registration Act Enforcement Priorities

In a memorandum published on February 5, 2025, newly confirmed Attorney General Pam Bondi announced sweeping standards for the Department of Justice’s (DOJ’s) exercise of prosecutorial discretion and charging decisions. The...more

Baker Botts L.L.P.

Compliance, Enforcement, and Litigation Risk Considerations from President Trump’s Executive Order on Designating New Foreign...

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On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” The order directs the...more

Holland & Knight LLP

Executive Order: Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global...

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Date Issued: Jan. 20, 2025 This executive order initiates the process of designating certain international cartels as Foreign Terrorist Organizations (FTOs) to address the rise in violence and terror across the western...more

Akin Gump Strauss Hauer & Feld LLP

National Security Presidential Memorandum/NSPM-2 (Trump EO Tracker)

Imposes maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist groups. Relevant Secretaries are required to impose and enforce sanctions,...more

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