On June 9, 2025, the Deputy Attorney General issued a Memorandum detailing the administration’s new FCPA guidelines for all current and future investigations and enforcement actions. According to the Head of DOJ’s Criminal...more
On March 20, 2025, the United Kingdom, France and Switzerland jointly announced the formation of a new International Anti-Corruption Prosecutorial Taskforce (the “Task Force”) aimed at strengthening cross-border collaboration...more
5/13/2025
/ Anti-Corruption ,
Corporate Counsel ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Government Agencies ,
Switzerland ,
UK
UPDATE: President Signs Executive Order Directing DOJ to Pause All FCPA Enforcement for 180 Days - On February 10, 2025, President Trump issued an Executive Order directing the U.S. Department of Justice (DOJ) to pause all...more
On June 26, 2024, the U.S. Supreme Court held 6-3 in Snyder v. United States that a federal statute, 18 U.S.C. § 666(a)(1)(B), does not criminalize “gratuities” to state and local officials—i.e., payments made to those...more
Key Points -
The SEC and the FCA each publish annual reports, which can offer a useful insight into their enforcement actions.
The data in the reports only represents a snapshot of the regulators’ activities, but is...more
• The prosecution of individuals remains a key priority for DOJ FCPA enforcement actions.
• DOJ is “busier than ever,” focused on “higher-priority,” “bread-and-butter,” and “meat-and-potatoes” cases.
• There is no...more
• The voluntary disclosure of a Foreign Corrupt Practices Act (FCPA) violation, “full cooperation” in an ensuing investigation, and timely and appropriate remediation, will create a presumption that the disclosing company...more
12/4/2017
/ Anti-Corruption ,
Attorney General ,
Cooperation ,
Corporate Fines ,
Department of Justice (DOJ) ,
Disgorgement ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
Memorandum of Guidance ,
Remediation ,
Restitution ,
Self-Reporting ,
Substantial Aggravating Circumstances ,
Voluntary Disclosure
On November 10, 2014, the Supreme Court (No. 14-389) declined to review the 3rd Circuit decision (No. 13-1237), In Re: Grand Jury Subpoena, leaving intact the 3rd Circuit’s ruling on the proper bounds of the crime-fraud...more
On October 6, 2014, the Supreme Court declined to review the 11th Circuit’s decision in U.S. v. Esquenazi, et. al., leaving standing the appellate court’s expansive definition of “foreign official” under the Foreign Corrupt...more
Companies all over the globe are increasingly aware of the record number of corporate criminal enforcement actions brought in recent years by enforcement authorities to combat corruption, and many companies now are also...more