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New FCPA Guidelines: Implications for US–French Cross-border Investigations

Recent guidance on US enforcement of the Foreign Corrupt Practices Act (FCPA) has significantly altered the landscape for cross-border investigations. Following President Donald Trump’s February 10, 2025 Executive Order...more

Implications of the New FCPA Guidelines on U.S./French Cross-Border Investigations

The new guidance on U.S. enforcement of the Foreign Corrupt Practices Act (FCPA) has significantly altered the landscape for cross-border investigations. President Trump’s February 10, 2025 Executive Order paused FCPA...more

DOJ’s Revised Policy on Crediting Fines: Emphasis on Victims

Without fanfare, the Department of Justice (DOJ or the Department) has published a memorandum revising its policy on when – and how – it will give credit to companies for fines and other payments made to other agencies,...more

DOJ’s New FCPA Guidelines: The Next Chapter in US Foreign Corruption Enforcement

The Department of Justice (DOJ) has released long-awaited guidance (FCPA Guidelines) regarding its approach to enforcement of the Foreign Corrupt Practices Act (FCPA) following the Executive Order (EO) pausing FCPA...more

Long-Awaited DOJ Guidance on White Collar Enforcement Priorities and Policies: Key Takeaways

This guidance follows a number of Executive Orders (EOs) and other memoranda from the DOJ, including (1) the February 10, 2025 EO pausing enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days, pending the...more

DOJ and SEC Send Warning on “AI Washing” with Charges Against Technology Startup Founder

The US Department of Justice (DOJ) announced a criminal indictment and the Securities and Exchange Commission (SEC) announced a civil complaint against the founder and former CEO of an e-commerce technology startup. DOJ and...more

SEC Roundtable Presents Both Risks and Opportunities of AI in the Financial Industry

The Securities and Exchange Commission (SEC) recently hosted a Roundtable on Artificial Intelligence in the Financial Industry in Washington, DC (SEC AI Roundtable). The day-long event, which took place on March 27, 2025,...more

How FCPA and FCA Enforcement Could Change Under President Trump

To date, President Donald Trump has signed close to 100 Executive Orders (EOs) that signal the Trump Administration’s policies and key priorities, including objectives related to corporate crime and international trade and...more

President Trump’s Executive Order Pauses FCPA Enforcement Pending Attorney General Review

On February 10, 2025, President Donald Trump signed an Executive Order (EO) directing Attorney General (AG) Pam Bondi to pause enforcement of the Foreign Corrupt Practices Act (FCPA) until new enforcement guidelines and...more

DOJ's Revised ECCP Signals Expectations of a Data-driven Compliance Program

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced much-anticipated revisions to the US Department of Justice (DOJ)’s Evaluation of Corporate Compliance Programs (Revised ECCP)...more

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