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The State of FARA Following Attorney General Bondi’s Reprioritization of DOJ Resources

On her first day in office, Attorney General Pam Bondi published several memorandums laying out the reprioritization of US Department of Justice (DOJ) efforts and funding, including the memorandum General Policy Regarding...more

DOJ Officials Commit to Aggressive FCA Enforcement, Signal Its Value and Direction

In remarks delivered at the Federal Bar Association’s (FBA) annual Qui Tam Section Conference, Deputy Assistant Attorney General Michael Granston reiterated the US Department of Justice’s (DOJ or the Department) commitment to...more

US Administration Tariff Expansion, Potential False Claims Act Actions, and Other Enforcement Implications

With the second Trump administration holding the reins of the executive branch, companies should brace for a renewed focus on trade enforcement. The administration has already begun to expand tariffs on a variety of items...more

DOJ’s Latest Attempt at Modernizing FARA Signals Greater Focus on Compliance and Enforcement

Following a decade of increased enforcement of what has been considered an oft-confusing law, the Department of Justice recently published a Notice of Proposed Rulemaking proposing several changes to regulations implemented...more

DOJ Criminal Division’s Corporate Enforcement Policy: Is 2023 the Year of the Carrot?

The US Department of Justice (DOJ) continues to try to dispel lingering skepticism over the benefits of corporate disclosure and cooperation. In remarks delivered on January 17, Assistant Attorney General (AAG) Kenneth A....more

Beware Congressional Oversight in FTX/Alameda Investigations

The House of Representatives and the Senate took the first steps in response to the collapse of FTX this week. The Senate Agriculture Committee has announced a hearing at which the chair of the Commodity Futures Trading...more

DOJ Civil Division Announces New Guidance on Inability-to-Pay Claims

The US Department of Justice’s Civil Division on September 4 issued detailed internal guidance on how the Division should evaluate and handle inability-to-pay claims by entities. Acting Assistant Attorney General Ethan P....more

DOJ and SEC Issue Long-Awaited Update to FCPA Resource Guide

On Friday, July 3, the US Department of Justice (DOJ) Criminal Division and the Securities and Exchange Commission (SEC) published the Second Edition of A Resource Guide to the U.S. Foreign Corrupt Practices Act, the...more

DOJ Assistant AG Benczkowski Discusses Use of Agency Liability Theory in FCPA Prosecutions

Assistant Attorney General Brian Benczkowski delivered remarks on December 4 at the American Conference Institute’s 36th International Conference on the Foreign Corrupt Practices Act. AAG Benczkowski addressed the US...more

DOJ: Corporate Compliance Programs Must Be Truly Effective

In its updated guidance issued on Tuesday, the US Department of Justice Criminal Division places effectiveness at the epicenter of its factors to be utilized when evaluating a company’s compliance program in the context of a...more

US Deputy Assistant Attorney General Reinforces Importance of Transparency in M&A Compliance Programs

US Deputy Assistant Attorney General Matthew S. Miner recently delivered remarks at a forum on anti-corruption compliance, where he highlighted the Department of Justice’s growing efforts to increase transparency between DOJ...more

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