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National Security Bribery

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

Cozen O'Connor

DOJ Restarts Enforcement of Foreign Corrupt Practices Act, Focusing on U.S. Interests

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On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum titled "Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)." The memo follows a four-month review triggered by...more

ArentFox Schiff

DOJ Issues New Guidelines for FCPA Investigation and Enforcement

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On June 9, Deputy US Attorney General Todd Blanche issued a memorandum outlining new guidelines for the enforcement of the Foreign Corrupt Practices Act (FCPA)....more

DLA Piper

DOJ’s New FCPA Guidelines: The Next Chapter in US Foreign Corruption Enforcement

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The Department of Justice (DOJ) has released long-awaited guidance (FCPA Guidelines) regarding its approach to enforcement of the Foreign Corrupt Practices Act (FCPA) following the Executive Order (EO) pausing FCPA...more

Eversheds Sutherland (US) LLP

DOJ issues updated guidance focused on protecting US companies

On June 9, 2025, US Department of Justice (DOJ) Deputy Attorney General Todd Blanche issued “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (Guidelines), instructing prosecutors...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

Hogan Lovells

DOJ's pause on FCPA is a compliance shake up for businesses

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This article was originally published by Bloomberg Law on April 10, 2025, and is republished here with permission. Read the original article here: DOJ’s Pause on FCPA Is a Compliance Shake-Up for Businesses – Bloomberg Law. ...more

Lathrop GPM

Trump Executive Order Pausing FCPA Enforcement: Have Legal Requirements Changed?

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One of the most notable developments in the anti-corruption world is the Trump Administration’s Feb. 10 Executive Order, “Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security.” ...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

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

Wiley Rein LLP

[Podcast] The Iron Fist of General Sani Abacha, Nigeria's Ruthless Dictator

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Join hosts Tatiana Sainati and Diana Shaw as they delve into the gripping story of General Sani Abacha, the Nigerian dictator who embezzled billions of dollars and ruled with an iron fist from 1993 to 1998. Known for his...more

Foley & Lardner LLP

Business Impacts of Trump’s Executive Order Pausing FCPA Enforcement

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On February 10 President Trump issued an Executive Order, Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security, signaling a shift in U.S. enforcement priorities regarding...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

BakerHostetler

Why Your Company Still Needs to Care About the FCPA (& FEPA)

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This shift in FCPA enforcement priorities is the latest move by the administration in its all-out war against cartels and TCOs that pose a threat to U.S. national security and its stated America First agenda. Additionally,...more

Baker Botts L.L.P.

Yes, Bribes Are Still Illegal, and Other Takeaways from the Pause on Foreign Corrupt Practices Act Enforcement

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On February 10, 2025 President Trump issued an executive order titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” The order directs the DOJ to halt Foreign Corrupt...more

The Volkov Law Group

Taking Stock of the FCPA Fallout (Part III of V)

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What an amazing turn of events? — Who would have predicted that the Trump Administration would take such a bold action in the name of advancing “American Competitiveness.” I admit I did not see this coming — the Trump...more

DLA Piper

President Trump’s Executive Order Pauses FCPA Enforcement Pending Attorney General Review

DLA Piper on

On February 10, 2025, President Donald Trump signed an Executive Order (EO) directing Attorney General (AG) Pam Bondi to pause enforcement of the Foreign Corrupt Practices Act (FCPA) until new enforcement guidelines and...more

Kilpatrick

President Trump Hits "Pause" (But Not "Stop"): The Scope of the New Executive Order on The DOJ's FCPA Enforcement Against American...

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Key Takeaways: The Executive Order’s 180-day pause on the DOJ’s FCPA enforcement does not eliminate many corruption and bribery risks. The Executive Order is limited in that it does not currently affect enforcement by...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

Ropes & Gray LLP

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

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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

Adams & Reese

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

Wiley Rein LLP

Senator Menendez Found Guilty of Corruption & Acting as a Foreign Agent

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Senator Bob Menendez (D-NJ), former Chair of the U.S. Senate Committee on Foreign Relations, has been found guilty in his federal corruption case for, among other things, bribery, obstruction of justice, and acting as a...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

The Volkov Law Group

Lessons Learned from the SAP Enforcement Action — DOJ Changes Tack on FCPA Enforcement While SEC Digs into Third-Party Controls...

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A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you.  I know I am scratching my head trying to make sense of the whole picture here.  There are a number of significant indicators of a...more

BakerHostetler

Congress Expands DOJ’s Power to Prosecute Corruption with the Foreign Extortion Prevention Act

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Adding to federal prosecutors’ tool kit in fighting global corruption, on December 14, 2023, Congress passed with bipartisan support, the Foreign Extortion Prevention Act (FEPA). As part of the National Defense Authorization...more

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