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National Security Securities and Exchange Commission (SEC) Enforcement Actions

DLA Piper

The Second Trump Administration’s First 100 days

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The first 100 days of the second Trump Administration have been marked by a flurry of Executive Orders (EOs) and policy memoranda intended to advance President Donald Trump’s “America First” agenda. In the process, these...more

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

Hinshaw & Culbertson - Consumer Financial...

An In-House Compliance Guide for Responding to President Trump's Executive Order on Foreign Corrupt Practices Act Enforcement

As has widely been published, on February 10, 2025, President Trump signed Executive Order (EO) 14209, which paused all future investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA) for at least...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

BakerHostetler

White House Increases Scrutiny on Foreign Investors: Why FOCI Is a Concern for International Businesses

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Foreign Ownership, Control, or Influence (FOCI) refers to a situation where a foreign entity has the power to directly or indirectly influence the management or operations of a company. FOCI can result from legal means like...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

Foley Hoag LLP

Trump Administration Pauses FCPA Enforcement – Why Compliance Is Still Critical

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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

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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

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

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

Fox Rothschild LLP

Trump Executive Order Pauses FCPA Enforcement

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Raising questions about the future of U.S. anti-corruption policy, President Trump has temporarily paused enforcement of the Foreign Corrupt Practices Act (FCPA),. An Executive Order (EO) signed on Feb. 10, 2025, Pausing...more

DLA Piper

SEC Actions Signal Warning to Investment Advisers Over-Promising on AML

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Earlier this month, the US Securities and Exchange Commission (SEC) charged a registered investment adviser (RIA) with willfully violating Section 206(4) of the Investment Advisers Act of 1940 by making misrepresentations...more

Akin Gump Strauss Hauer & Feld LLP

Ending The Weaponization Of The Federal Government

This EO sets forth a process to seek accountability for the previous administration’s perceived weaponization of the federal government’s powers, focusing on the use of the Intelligence Community, Department of Justice,...more

McDermott Will & Emery

SEC Settlements Signal Increased Scrutiny of Cybersecurity Disclosures

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On October 22, 2024, the US Securities and Exchange Commission (SEC, or Commission) brought settled actions against four publicly traded companies that were downstream victims of the Russia-linked cyberattack on SolarWinds...more

Foley Hoag LLP - White Collar Law &...

A Preview of SEC, CFTC, AML, Sanctions and CFIUS Enforcement Priorities Under the Second Trump Administration

As the incoming Trump administration prepares to take office, businesses and investors can expect significant shifts in the enforcement priorities of the Securities and Exchange Commission (SEC) and the Commodity Futures...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

Sheppard Mullin Richter & Hampton LLP

For Limited Use Only: Guidance on National Security Delay Determinations under the SEC Cyber Reporting Rule

On December 12, 2023, the Department of Justice (“DOJ”) issued guidance related to the process by which companies may request the United States Attorney General authorize delays of cyber incident disclosures, pursuant to a...more

Skadden, Arps, Slate, Meagher & Flom LLP

Recent Trends in China-Related Cross-Border Enforcement

Key Points and Practical Advice In February 2022, the U.S. Department of Justice (DOJ) announced that the China Initiative, launched in November 2018 to counter perceived threats to U.S. national security from China, was...more

Perkins Coie

Answers to Common Questions Regarding New CIRCIA

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President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) on March 15, 2022. The enactment of CIRCIA follows attacks on critical infrastructure, such as the May 2021...more

Pillsbury Winthrop Shaw Pittman LLP

Twelve Hours to Get It Right: The SEC Intensifies Its Focus on Cybersecurity

The SEC’s recent enforcement actions, public statements and proposed rulemaking indicate that cybersecurity will be an area of heightened focus for the Gensler Commission. New proposed rules would require public companies...more

McDermott Will & Emery

[Webinar] 2022 Enforcement Outlook Series - Foreign Corrupt Practices Act/Anti-Corruption - March 8th, 12:00 pm - 1:00 pm EST

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As expected when a new administration takes office, 2021 saw a surge in white-collar enforcement activity. There was a 12% increase in white-collar prosecutions during US President Joe Biden’s first year in office, and that...more

Goodwin

2021 Year in Review: FCPA

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A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

Porter Hedges LLP

Anti-Corruption Enforcement: 2021 Year-In-Review

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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

Holland & Knight LLP

Holland & Knight's China Practice Newsletter: September-October 2021

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Holland & Knight invites you to read our China Practice Newsletter, in which our authors discuss pertinent Sino-American topics. HIGHLIGHTS: - Non-Fungible Tokens and Intellectual Property Law: Key Considerations ...more

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