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

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

Curbing Regulatory Crimes: Latest Executive Order Warrants Close Attention by Corporate Legal and Compliance Teams

On May 9, 2025, President Donald J. Trump signed a new Executive Order titled Fighting Overcriminalization in Federal Regulations, marking a significant policy shift in how federal agencies and the Department of Justice (DOJ)...more

When is “Misleading” Not “False”? The Supreme Court's Decision in Thompson v. United States and Its Implications for Government...

On March 21, 2025, a unanimous Supreme Court held in Thompson v. United States that a federal statute prohibiting “false” statements to banks, 18 USC § 1014, does not apply to statements that are merely misleading. Although...more

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