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White Collar Crimes Foreign Corrupt Practices Act (FCPA) Executive Orders

Latham & Watkins LLP

DOJ Focuses FCPA Enforcement With New Guidelines

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DOJ issues updated guidelines, ending temporary “pause” on FCPA enforcement and focusing potential enforcement on priority areas. On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the Guidelines)...more

Jenner & Block

Client Alert: Back in Action: The Trump Administration Lifts “Pause” in Foreign Corrupt Practices Act Enforcement

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Approximately four months after President Trump imposed a pause on new Foreign Corrupt Practice Act (FCPA) investigations and enforcement actions, the US Department of Justice (DOJ) has issued new guidelines lifting that...more

Bass, Berry & Sims PLC

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

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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

Hogan Lovells

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

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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

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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

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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

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

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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

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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

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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

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

Baker Donelson

DOJ Dismisses FCPA Charges Against Former Cognizant Executives Following New Policy

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On April 2, 2025, the U.S. Department of Justice (DOJ) moved to dismiss the Foreign Corrupt Practices Act (FCPA) case against former Cognizant Technology Solutions Corp. executives Gordon Coburn and Steven Schwartz, United...more

A&O Shearman

Criminal Case Against Former Executives Of Technology Company Dismissed

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On April 2, 2025, the Department of Justice moved to dismiss with prejudice its Foreign Corrupt Practices Act (“FCPA”) case against two former executives of a technology solutions company (“Company”). The executives were...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for February 2025

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

ArentFox Schiff

Predicting the Unpredictable: DOJ’s Enforcement Priorities From the ABA’s 40th White Collar Crime Institute

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ArentFox Schiff attorneys William Ziegelmueller and Kaitlin Klamann attended the American Bar Association’s (ABA) 40th White Collar Crime Institute (WCCI) March 5-7, 2025, in Miami, Florida. In the absence of representatives...more

A&O Shearman

US Attorney For The District of New Jersey Reverses Course And Requests Adjournment For Foreign Bribery Case Against Tech...

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On March 4, 2025, one day before a trial against former tech executives for alleged foreign bribery charges was set to commence, the United States Attorney for the District of New Jersey requested 180-day adjournment. The...more

Stikeman Elliott LLP

Foreign Bribery: The Bottom Line is that It’s Still Illegal Under Canadian Law

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It remains illegal under the Canadian Corruption of Foreign Public Officials Act (“CFPOA”) to bribe foreign officials. While this statement may be self-evident, recent developments south of the border prompt this reminder to...more

Vedder Price

Changed Focus of FCPA Actions Under Trump Executive Order

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On February 5, 2025, newly appointed U.S. Attorney General Pam Bondi issued a memorandum titled “Total Elimination of Cartels and Transnational Criminal Organizations” (the February 5 Memorandum), which outlined a broad...more

Jenner & Block

Client Alert: The Trump Administration Calls for a Pause on New FCPA Enforcement, but Don’t Abandon Compliance Programs Just Yet

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In an executive order issued on February 10, 2025 (Executive Order), and a memorandum issued by Attorney General Pam Bondi regarding cartels and transnational criminal organizations on February 5, 2025 (Cartel Memo), the...more

McCarter & English, LLP

Trump Administration Shifts DOJ’s Approach to FCPA Enforcement

On February 10, 2025, President Trump signed an Executive Order (EO) directing Attorney General Pam Bondi to halt ongoing enforcement by the Department of Justice (DOJ) in all active prosecutions brought pursuant to the...more

ArentFox Schiff

Investigations Newsletter: President Trump Puts a “Pause” on FCPA Enforcement

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President Trump Puts a “Pause” on FCPA Enforcement - On Monday, President Donald Trump signed an executive order (EO) pausing the enforcement of the Foreign Corrupt Practices Act (FCPA). According to the EO, the pause will...more

K&L Gates LLP

President Trump Orders FCPA Freeze; DOJ Announces Major Policy Realignment De-Emphasizing Corporate Investigations and Enforcement

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The much-heralded end to prosecutions brought pursuant to the Foreign Corrupt Practices Act (FCPA) never materialized during the first Donald Trump administration, but Trump 2.0 has the potential to bring major change to the...more

Alston & Bird

Pause and Effect: The Trump Administration Takes Aim at the FCPA

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Our White Collar, Government & Internal Investigations Team examines the impact of President Trump’s Executive Order pausing enforcement of the Foreign Corrupt Practices Act and identifies some key considerations and...more

McGuireWoods LLP

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

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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

Cozen O'Connor

U.S. Dials Back Implementation of Foreign Corrupt Practices Act

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On February 10, 2025, President Trump signed an executive order instructing the Department of Justice (DOJ) and Attorney General (AG) Pamela Bondi to “cease initiation of any new [Foreign Corrupt Practices Act (FCPA) (15...more

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