On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the “Blanche Memorandum”) detailing new guidelines for the Department of Justice’s approach to investigating and enforcing the Foreign Corrupt...more
We have previously written about the impact of the pause in enforcement of the FCPA implemented by the Trump Administration on non-American companies.1 Although the 180-day review period the Executive Order provided to the...more
4/29/2025
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
EU ,
Foreign Corrupt Practices Act (FCPA) ,
Popular ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
UK
How the New Law Creates Legal Risks and Opportunities for International Businesses -
On December 22, 2023, President Biden signed into law the 2024 National Defense Authorization Act (NDAA), which will give the U.S....more
1/5/2024
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Department of Justice (DOJ) ,
Enforcement ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
NDAA ,
Popular ,
Securities Exchange Act of 1934 ,
Travel Act ,
Wire Fraud
To close out 2021, enforcement authorities throughout the Americas continued to investigate fraud, corruption, and other misconduct across the region. For 2022, we expect an uptick of anticorruption investigations as a...more
3/4/2022
/ Anti-Corruption ,
Anti-Money Laundering ,
Biden Administration ,
Corporate Counsel ,
Corruption ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
El Salvador ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Guatemala ,
Honduras ,
Latin America ,
OECD
This summary is part of our regular reporting of trends and developments related to investigations and enforcement activity into fraud, corruption, and other misconduct by authorities in the United States and the Americas and...more
8/9/2021
/ Anti-Corruption ,
Austria ,
Banks ,
Biden Administration ,
Brazil ,
Bribery ,
DEA ,
Department of Justice (DOJ) ,
Enforcement Actions ,
EU ,
FBI ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Guatemala ,
Investigations ,
Latin America ,
Mexico ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
UK
Enforcement authorities throughout the Americas continued investigations of fraud, corruption, and other misconduct across the region. Below are some of the highlights of the last quarter. ...more
5/28/2021
/ Brazil ,
Bribery ,
Corruption ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Markets ,
Foreign Corrupt Practices Act (FCPA) ,
Latin America ,
Mexico ,
Money Laundering ,
Popular ,
Venezuela ,
White Collar Crimes ,
Wiretapping
As 2020 drew to a close, enforcement authorities throughout the United States and the Americas continued to investigate fraud, corruption, and other misconduct across the region. In this newsletter, we highlight some...more
3/11/2021
/ Bank Secrecy Act ,
Brazil ,
Bribery ,
CFTC ,
Corporate Transparency Act ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Drug Trafficking ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Money Laundering ,
NDAA ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
Whistleblower Awards ,
Whistleblowers
As 2020 drew to a close, enforcement authorities throughout the United States and the Americas continued to investigate fraud, corruption, and other misconduct across the region. Below, we highlight some developments from...more
1/22/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Brazil ,
Bribery ,
CFTC ,
Consumer Protection Act ,
Corporate Transparency Act ,
Corruption ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Drug Trafficking ,
Ecuador ,
Enforcement Actions ,
Enforcement Authority ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Latin America ,
Mexico ,
Money Laundering ,
NDAA ,
Securities and Exchange Commission (SEC) ,
Sweden ,
Whistleblowers
DOJ Enforcement in Latin America Continues Despite Pandemic -
During the 3rd quarter, the Department of Justice made a number of high-profile arrests and concluded plea agreements in several cases related to Latin...more
11/24/2020
/ Anti-Corruption ,
Anti-Money Laundering ,
Appeals ,
Bribery ,
Department of Justice (DOJ) ,
Embezzlement ,
Extradition ,
Foreign Corrupt Practices Act (FCPA) ,
Latin America ,
Mexico Supreme Court of Justice ,
Money Laundering ,
National Security Agency (NSA)
In the fourth quarter of 2019, U.S. enforcement authorities sustained efforts to prosecute individuals violating U.S. anticorruption laws in matters related to Latin America, while authorities in Latin America, including in...more
1/22/2020
/ Anti-Corruption ,
Asset Seizure ,
Brazil ,
Bribery ,
Corruption ,
Criminal Convictions ,
Criminal Investigations ,
Criminal Liability ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Enforcement Authority ,
Export Controls ,
Financial Crimes ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Guilty Pleas ,
Legislative Vetoes ,
Mexico ,
Peru ,
Sanction Violations ,
Statutory Authority ,
Voluntary Disclosure
Enforcement authorities throughout the United States and the Americas continue to aggressively investigate fraud and corruption across the region in the third quarter of 2019. Below, we highlight some recent developments and...more
10/14/2019
/ Airlines ,
Anti-Corruption ,
Argentina ,
Aviation Industry ,
Brazil ,
Bribery ,
Chile ,
Compliance ,
Corporate Investigations ,
Corruption ,
Criminal Convictions ,
Criminal Penalties ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Ecuador ,
Enforcement Authority ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Government Investigations ,
Indictments ,
Kickbacks ,
Latin America ,
Mexico ,
Money Laundering ,
Peru ,
Popular ,
Securities and Exchange Commission (SEC) ,
United States-Mexico-Canada Agreement (USMCA)
The U.S. Justice Department, the U.S. Securities and Exchange Commission, and their enforcement partners throughout Latin America remain focused on actively investigating corruption activities and bringing enforcement actions...more
7/1/2019
/ Anti-Corruption ,
Brazil ,
Chief Compliance Officers ,
Compliance ,
Corruption ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement ,
FBI ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Latin America ,
Medical Devices ,
Mexico ,
Pharmaceutical Industry ,
Self-Disclosure Requirements
On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas.[i] In issuing the new document...more
5/6/2019
/ Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Employee Training ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Guidance Update ,
Multinationals ,
Risk Assessment ,
Risk Management ,
Training ,
Whistleblower Hotlines ,
Whistleblowers
Argentina’s corruption notebooks scandal is just as it sounds—a scandal initiated by eight notebooks documenting at least seven years of elaborate corruption schemes involving senior officials in Argentina’s government. The...more
Recently, and without the fanfare that often accompanies new policy guidance regarding corporate fraud, the Fraud Section of the Department of Justice posted a document on its website entitled “Evaluation of Corporate...more