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DOJ Resumes FCPA Enforcement with a New “America First” Focus on Energy and Other Vital National Interests — Creating...

On June 9, 2025, Deputy Attorney General Todd Blanche announced that the U.S. Department of Justice (“DOJ” or the “Department”) will resume investigating and prosecuting violations of the U.S. Foreign Corrupt Practices Act...more

Focus, Fairness, & Efficiency: DOJ White Collar Policy Shifts Signal Recalibration, But Not Revolution in Enforcement

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (“DOJ” or the “Department”) issued a series of significant policy changes outlining the Trump administration’s new approach to white-collar enforcement....more

Corporate Transparency Act: Once Again Enforceable – New Compliance Dates Apply

As we previously discussed, on January 7, 2025, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction delaying the implementation of the Corporate Transparency Act’s (“CTA”) reporting...more

Future of FCPA Enforcement Uncertain (For Now) as New Administration Revamps the Law Enforcement Toolkit

Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more

Supreme Court Grants Stay of Preliminary Injunction Against Corporate Transparency Act – Second Injunction Still In Effect

On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry. As we discussed previously,...more

Whistleblowers Wanted: Proliferation of DOJ Whistleblower Policies Invites Harmonization by the Trump Administration

As Donald J. Trump prepares to begin his second presidential administration on January 20, 2025, many Department of Justice (“DOJ”) priorities and policies are likely to change. One new Biden administration initiative that is...more

New Year and New Administration: DOJ Races to Clear Its FCPA Docket Before the Trump Administration Begins

As we approach Inauguration Day on January 20, 2025, one question among anticorruption practitioners is how the Trump administration will handle enforcement of the Foreign Corrupt Practices Act (“FCPA”). In the meantime, we...more

FinCEN’s Response to Nationwide Preliminary Injunction Against Enforcement of the Corporate Transparency Act

As we previously discussed, on December 3, 2024, Judge Amos Mazzant of the U.S. District Court for the Eastern District of Texas issued a memorandum opinion and order granting a nationwide preliminary injunction against the...more

DOJ Warns Against Unintelligent Use of Artificial Intelligence

The Department of Justice is stepping up its focus on artificial intelligence (“AI”), with officials warning that harsher penalties could be in store for those who deliberately misuse the technology to commit white collar...more

[CLE Hybrid Event] To Self-Report or Not to Self-Report: DOJ's New ‘Safe Harbor’ Policy Tries to Answer the Question for M&A Cases...

It is one of the hardest questions a company can face: after discovering criminal conduct inside your company, do you self-report to the government or not? The reality is that when faced with the question of self-reporting,...more

Holiday Jeers: How The Grinch at DOJ May Make It Harder for Companies to Stay on the Nice List This Christmas

With the holiday season upon us, companies waiting for a nice surprise this Christmas are more likely to find a lump of coal in their stocking. In a series of recent announcements, Department of Justice (“DOJ”) officials have...more

World Bank’s “Major Initiative” Should Enhance Evaluations Of Corporate Compliance Programs

During a roundtable at the Fifth International Debarment Colloquium last month, Joseph Mauro, a spokesperson for the Compliance Unit of the World Bank Group’s (“World Bank”) Integrity Vice Presidency (“INT”), announced recent...more

Venezuela’s CITGO Joins Other Companies And State-Owned Entities Seeking To Claim Victim Status And Restitution In FCPA Cases

In a novel and aggressive move likely aimed at garnering goodwill with federal regulators, Venezuelan state-owned entity CITGO Petroleum Company (“CITGO”) has sued its former agent for harm CITGO alleges was caused by the...more

Paycheck Protection Program Loan Borrowers Beware: SEC Turns Attention To Public Borrowers

Scrutiny into Paycheck Protection Program Loans Intensifies — Attracts SEC Attention- Public companies applying for Paycheck Protection Program (“PPP”) loan funds have been under increasing political and media scrutiny....more

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