News & Analysis as of

Risk Management Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA)

Morgan Lewis

Cartels, TCOs, ‘Instrumentalities of a Government’: Reassessing FCPA Risk Amid Shifting US Enforcement Priorities

Morgan Lewis on

Whether cartels do or do not qualify as “instrumentalities of a government” under current FCPA law or based on the AG’s forthcoming revised FCPA guidance, their entanglement with corrupt officials and influence over local...more

Hogan Lovells

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

Hogan Lovells on

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

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

DLA Piper

From the US to Brazil: Tackling Corruption Risks in M&A

DLA Piper on

Corporate transactions, especially mergers and acquisitions (M&A), have become pivotal strategies for growth in an increasingly globalized economy. However, with this expansion comes the responsibility of navigating complex...more

TransPerfect Legal

Rethinking Risk: Insights from FCPA Houston 2025

TransPerfect Legal on

Top compliance professionals, legal experts, and enforcement officials gathered to explore the evolving anti-corruption landscape during the American Conference Institute (ACI)’s 18th Forum on the Foreign Corrupt Practices...more

Ankura

Internal Control Lessons Learned from Global Anti-Corruption Enforcement in 2024

Ankura on

2024 saw another strong year of Foreign Corruption Practices Act (FCPA) enforcement actions from the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). There were 15 resolutions with...more

Ankura

Balancing Courtesy and Compliance: Best Practices in Corporate Hospitality

Ankura on

Whether part of local customs, relationship building or ways to give thanks, gift giving and hospitality (collectively referred to here as “Hospitality”) is a sizable business, with the global market being estimated at USD839...more

Hogan Lovells

Caught in the crosshairs: Mitigating supply chain risks from Cartel FTO designations

Hogan Lovells on

On February 20, the U.S. Department of State (State) designated eight cartels as Foreign Terrorist Organizations (FTOs). These designations are the latest development in the Trump administration’s realignment of the U.S....more

Womble Bond Dickinson

Compliance Still Matters: The Future of FCPA Enforcement

Womble Bond Dickinson on

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

The Volkov Law Group

Updating Your Risk Profile to Respond to the New Trump Administration

The Volkov Law Group on

We live in a topsy-turvy world.  This is an exaggeration but sets up my points in this blog post. We are now seeing the shuffling of corporate risks and every board, C-Suite and legal, compliance and risk management team has...more

McGuireWoods LLP

Practical Tips for Companies Following President Trump’s Pause on FCPA Enforcement

McGuireWoods LLP on

Since the President signed the February 10, 2025 Executive Order (Order) pausing enforcement of the Foreign Corrupt Practices Act (FCPA) (Client Alert: President Trump issues Executive Order “Pausing Foreign Corrupt Practices...more

Porter Hedges LLP

Breaking Alert: New Executive Order Temporarily Pauses FCPA Enforcement

Porter Hedges LLP on

On February 10, 2025, President Trump signed an executive order (EO) directing the Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days. During this period, Attorney...more

American Conference Institute (ACI)

An FCPA Enforcement Pause Does Not Pause Anti-Corruption Compliance

U.S. Foreign Corrupt Practices Act (FCPA) enforcement activity may be at a temporary standstill, but that should not mean much for the day-to-day operations of global anti-corruption compliance programs. If the Department of...more

Proskauer Rose LLP

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

Proskauer Rose LLP on

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

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

Wiley Rein LLP

What the FCPA Criminal Enforcement Pause Means for Companies

Wiley Rein LLP on

Late on February 10, President Trump ordered Attorney General Pam Bondi to “pause” new Foreign Corrupt Practices Act (FCPA) enforcement for 180 days while the U.S. Department of Justice (DOJ) refocuses criminal enforcement of...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 12th - 13th, Polanco, CDMX, Mexico

Connect with the leading Anti-Corruption experts and discuss the latest compliance strategies at ACI’s Mexico Summit on Anti-Corruption & Compliance Programs. As Mexico’s longest running, premier anti-corruption and...more

Kohrman Jackson & Krantz LLP

Client Alert: Executive Order Suspends Enforcement of Foreign Bribery Law

On February 10, 2025, President Donald J. Trump signed an Executive Order pausing enforcement actions under the Foreign Corrupt Practices Act (FCPA), citing concerns that excessive enforcement was harming American businesses...more

Dorsey & Whitney LLP

Should Your Company Shut Down Its Anti-Corruption Compliance Program and Start Paying Bribes? Here Are a Few Reasons to Think...

Dorsey & Whitney LLP on

On February 10, 2025, President Trump issued a new Executive Order (“EO”) titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” This EO comes on the tail of Attorney...more

NAVEX

The Importance of Benchmarking Your Compliance Program

NAVEX on

Sometimes questions about corporate compliance programs can be more complicated than they first seem. Such was the case when a compliance officer recently asked me, “Can you point to anything specific that says why compliance...more

Bracewell LLP

Keeping an Eye on AI: DOJ Updates its Playbook for Corporate Compliance

Bracewell LLP on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more

Thomas Fox - Compliance Evangelist

Root Cause Analysis Lessons from Star Trek: The Corbomite Maneuver

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Thomas Fox - Compliance Evangelist

Lessons on Incentives and Discipline from Star Trek: Mirror Mirror

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Thomas Fox - Compliance Evangelist

Risk Assessment Lessons from Star Trek: Balance of Terror

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

NAVEX

Sanctions are the “New” FCPA – How this Era of Enforcement Shapes Third-Party Risk Management

NAVEX on

In the summer of 2022, Deputy Attorney General Lisa Monaco – a veteran prosecutor and currently number two at the helm of the U.S. Department of Justice (DOJ) – began to describe the enforcement of sanctions regulations as...more

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