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Reshaped Priorities: Navigating Changes to FCPA and FARA Enforcement

On February 10, 2025, President Donald Trump signed an Executive Order directing the Department of Justice (DOJ) to pause enforcement of the U.S. Foreign Corrupt Practices Act (FCPA), citing concerns over the competitive...more

Compliance Programs Must Track and Adapt to Changes and Risks

Updated DOJ Guidance calls on corporations to devote additional resources and attention to detect and prevent misconduct. A well-structured and effective compliance program must evolve with lessons learned, be understood...more

Time to Update Corporate Compliance Programs Following DOJ Guidance

Companies must now address three questions proactively. On April 30, 2019, the DOJ’s Criminal Division issued updated guidance on how it will evaluate corporate compliance programs in its charging decisions going forward....more

FinCEN Expands Scope of “All Cash” GTOs

Continuing its efforts to deter the use of real estate as a vehicle to launder proceeds of criminal activity, the Financial Crimes Enforcement Network (FinCEN) recently announced its plan to extend the reach and time frame of...more

New FCPA Self-Reporting Pilot Program Formalizes Rewards but Relies on Discretionary Implementation

On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more

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