News & Analysis as of

National Security Securities and Exchange Commission (SEC) Compliance

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

Foley Hoag LLP

Trump Administration Pauses FCPA Enforcement – Why Compliance Is Still Critical

Foley Hoag LLP on

On February 10, 2025, President Trump issued an executive order (EO) directing Attorney General Pam Bondi to effectively pause the Justice Department’s enforcement of the Foreign Corrupt Practices Act (FCPA). This was the...more

Seward & Kissel LLP

Pausing Bribery Prosecutions: What Companies Need to Know

Seward & Kissel LLP on

Last week President Trump signed an Executive Order pausing enforcement of the nation’s most robust anti-bribery statute, the Foreign Corrupt Practices Act (“FCPA”). The EO seeks a complete overhaul of the FCPA enforcement...more

Benesch

President Trump “Pauses” FCPA Enforcement: What This Means for Legal & Compliance Departments

Benesch on

On February 10, 2025, President Trump issued an Executive Order entitled Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security. The executive order comes just days after the...more

Baker Botts L.L.P.

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

Baker Botts L.L.P. on

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

Kilpatrick

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

Kilpatrick on

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

Guidepost Solutions LLC

Monitoring Against Whistleblower Retaliation

Guidepost Solutions LLC on

Saves Lives, Prevents Major Crimes, and Accelerates Voluntary Self - Disclosures The U.S. Department of Justice (“DoJ”) recently spotlighted its Whistleblower Awards Program and Voluntary Self Disclosure (“VSDs”)...more

DLA Piper

National Security Risks Headline New AML Requirements for Investment Advisers – and More to Come?

DLA Piper on

Last week, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a widely anticipated final rule to police the estimated $125 trillion-plus investment adviser market. The new rule extends...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...

The Volkov Law Group on

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

Mintz - Privacy & Cybersecurity Viewpoints

SEC Adopts Final Cybersecurity Rules for Public Companies

In a narrow 3-2 decision on July 26, the SEC adopted its final rule concerning cybersecurity risk management, strategy, governance, and incident disclosure (the “Final Rule”).  Below we highlight some of the principal changes...more

Pillsbury Winthrop Shaw Pittman LLP

SEC Finalizes Public Company Cybersecurity Disclosure Rules

Under the SEC’s rules, public companies that are subject to reporting requirements must promptly disclose material cybersecurity incidents. The SEC’s Final Rules require public companies to report a material cybersecurity...more

King & Spalding

DOJ Corporate Enforcement Policy Revisions Target Executive Compensation, Following Multi-Agency Trend

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On March 2, 2023 and March 3, 2023, in a pair of speeches by Deputy Attorney General (DAG) Lisa Monaco and Criminal Division Assistant Attorney General (AAG) Kenneth Polite, the U.S. Department of Justice (DOJ) announced...more

Porter Hedges LLP

Anti-Corruption Enforcement: 2021 Year-In-Review

Porter Hedges LLP on

As we look back on 2021, several anti-corruption enforcement trends emerge. The following summarizes the key developments of the prior year and trends to watch in 2022: The Department of Justice (“DOJ”) brought 24...more

Jones Day

FCPA 2021 Year In Review

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The Biden administration took office in January 2021, announcing aggressive and sweeping anticorruption initiatives to tackle corruption around the world, labeling corruption a national security priority, and signaling a...more

Miller Canfield

Biden Memorandum on Combating Corruption Likely Means Increased FCPA Enforcement

Miller Canfield on

Earlier this month, the Biden Administration formally announced that combating corruption is a core United States national security interest. On June 3, 2021, the Biden Administration issued a Memorandum on Establishing the...more

Thomas Fox - Compliance Evangelist

Whom Should You Suspend During an Internal Investigation?

Whom to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW) emission-testing scandal continues to...more

Thomas Fox - Compliance Evangelist

Compliance at the Tipping Point, Part IV – The Schrems Decision

I continue my exploration of why I believe that compliance is at the Tipping Point, with today’s entry of data point four, which is last week’s decision by the European Court of Justice (ECJ) in the Schrems case. While most...more

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