News & Analysis as of

White Collar Crimes Enforcement Actions Foreign Corrupt Practices Act (FCPA)

Cadwalader, Wickersham & Taft LLP

The Pause is Over—the FCPA Lives On

On June 9, 2025, the U.S. Department of Justice (DOJ) announced the resumption of Foreign Corrupt Practices Act (FCPA) enforcement, ending the enforcement pause initiated by Executive Order 14209. In doing so, Deputy Attorney...more

Bass, Berry & Sims PLC

Is the “Pause” Over? DOJ Resumes FCPA Enforcement, Announces Guidelines

Bass, Berry & Sims PLC on

On June 9, Deputy Attorney General Todd Blanche issued a memorandum entitled Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (the Memo) addressed to the head of the Criminal Division of the...more

BakerHostetler

FCPA Enforcement Is Back with a New Enhanced Focus on Protecting US Business Abroad, National Security, Individuals and (of...

BakerHostetler on

U.S. Department of Justice (DOJ) Deputy Attorney General Todd Blanche issued a memorandum on June 9 (the Memo), announcing DOJ will resume enforcement of the Foreign Corrupt Practices Act (FCPA) after its brief hiatus....more

Hogan Lovells

FCPA reloaded: The DOJ “unpauses” enforcement – But is it a new level?

Hogan Lovells on

On June 9, 2025, Deputy Attorney General Todd Blanche issued revised enforcement guidelines for the Foreign Corrupt Practices Act (FCPA), officially ending the FCPA enforcement pause that Executive Order 14209 (EO) instituted...more

Husch Blackwell LLP

DOJ Poised to Reboot FCPA Investigations and Enforcement

Husch Blackwell LLP on

Issued on February 10, 2025, Executive Order 14209 (“Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security”) called on the Department of Justice (DOJ) to “review guidelines and...more

Paul Hastings LLP

New DOJ FCPA Guidelines Target Cases Linked to US Strategic Interests

Paul Hastings LLP on

On June 9, U.S. Deputy Attorney General Todd Blanche issued a memorandum entitled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA),” which establishes guidelines to ensure that FCPA...more

Perkins Coie

FCPA Is Here to Stay: DOJ Reaffirms Commitment to Enforce FCPA

Perkins Coie on

On June 9, 2025, the U.S. Department of Justice (DOJ) unveiled new guidelines for enforcing the Foreign Corrupt Practices Act (FCPA), marking a pivotal shift in how corruption cases are pursued. The guidelines seek to...more

Skadden, Arps, Slate, Meagher & Flom LLP

Deputy Attorney General Issues FCPA Guidelines Resuming Limited Enforcement

Key Points - - The U.S. Department of Justice (DOJ) will resume investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA), prioritizing, in part, FCPA actions involving cartels and transnational...more

Ballard Spahr LLP

Focused FCPA Enforcement: Emphasizing Security and Strategic Interests

Ballard Spahr LLP on

On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the DAG memorandum) updating the Department of Justice’s (DOJ) enforcement guidelines for the Foreign Corrupt Practices Act (FCPA) in accordance with...more

Fenwick & West LLP

DOJ Unpauses FCPA Enforcement with New Limits

Fenwick & West LLP on

On February 10, 2025, the president signed an executive order that paused investigation and enforcement of the FCPA for a period of 180 days, required the DOJ to review any existing FCPA investigation or prosecution, and to...more

Baker Botts L.L.P.

Back from the Dead? Takeaways from US DOJ’s New Guidelines for FCPA Investigations and Enforcement

Baker Botts L.L.P. on

On June 9, 2025, the Deputy Attorney General of the United States Department of Justice issued “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (the “Memorandum”). The Memorandum...more

Cozen O'Connor

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

Cozen O'Connor on

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

ArentFox Schiff on

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

Vinson & Elkins LLP

Focus, Fairness, & Efficiency: DOJ White Collar Policy Shifts Signal Recalibration, But Not Revolution in Enforcement

Vinson & Elkins LLP on

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (“DOJ” or the “Department”) issued a series of significant policy changes outlining the Trump administration’s new approach to white-collar enforcement....more

Foley Hoag LLP

DOJ Announces New Priorities in White-Collar Criminal Enforcement: Targeting Waste, Fraud, and Abuse and Protecting American...

Foley Hoag LLP on

The U.S. Department of Justice’s ("DOJ") Criminal Division recently issued a memorandum outlining a shift in the DOJ’s priorities and policies for prosecuting white-collar crime (the “Memorandum”). Issued by the Head of the...more

DarrowEverett LLP

The DOJ’s New White-Collar Agenda: Implications for Businesses

DarrowEverett LLP on

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

Herbert Smith Freehills Kramer

DOJ Announces White-Collar Enforcement Priorities and Revised Corporate Enforcement & Voluntary Self-Disclosure Policy

On May 12, 2025, the Department of Justice (“DOJ” or the “Department”) issued a revised Corporate Enforcement and Voluntary Self-Disclosure Policy (Revised CEP). Matthew R. Galeotti, chief of the Criminal Division of the DOJ,...more

McCarter & English, LLP

DOJ Criminal Division Announces White Collar Enforcement Priorities and Policy Changes to White Collar Investigations

Earlier this week, the US Department of Justice (DOJ) released a new white collar enforcement plan (Enforcement Plan) outlining changes to the Criminal Division’s white collar enforcement priorities to align more closely with...more

Mayer Brown

DOJ Announces White-Collar Enforcement Priorities and Revised Policies

Mayer Brown on

On May 12, 2025, the Criminal Division of the US Department of Justice (DOJ) issued new guidance on white-collar enforcement priorities and revised its policies on corporate voluntary self-disclosure (VSD), the selection of...more

Hogan Lovells

DOJ corporate enforcement overhaul: More declinations, fewer monitors, and FCPA enforcement still in question

Hogan Lovells on

On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to key corporate criminal enforcement policies. The revisions’ stated aim is to provide more clarity and certainty of outcome to companies that...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ White Collar Enforcement Plan Continues To Present Risks for Non-US Companies

Matthew Galeotti’s recent memorandum as head of the Department of Justice’s (DOJ’s) Criminal Division echoes the Trump administration’s “America First” priorities. It directs the Criminal Division to “strike an appropriate...more

Ropes & Gray LLP

Department of Justice Announces Changes to Corporate Enforcement Policies; More Carrots and Sticks

Ropes & Gray LLP on

On May 12, 2025, at SIFMA’s annual Anti-Money Laundering and Financial Crimes Conference, the U.S. Department of Justice’s Criminal Division Chief announced a new White-Collar Enforcement Plan and accompanying changes to...more

White & Case LLP

Ten Takeaways from the DOJ Criminal Division’s New Playbook on White Collar Enforcement Priorities

White & Case LLP on

On May 12, 2025, the U.S. Department of Justice ("the DOJ" or "the Department") unveiled its new playbook for prosecuting white-collar and corporate crime. DOJ announced enforcement priorities for the Criminal Division ("the...more

Akin Gump Strauss Hauer & Feld LLP

DOJ’s Criminal Division Turns Page on White Collar Crime—But Keeps One Foot in the Past

On May 12, 2025, the DOJ announced a new “white-collar enforcement plan” identifying new corporate enforcement priorities and aiming to promote greater focus, fairness and efficiency in prosecuting corporate misconduct. In a...more

Wiley Rein LLP

DOJ Announces Changes to White Collar Enforcement Policies, Focusing on “Most Egregious” Crimes

Wiley Rein LLP on

This week, the U.S. Department of Justice (DOJ) announced the Criminal Division’s new white collar enforcement plan, changes to its Corporate Whistleblower Pilot Program, and revisions to the Corporate Enforcement and...more

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