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Ten Takeaways from the DOJ Criminal Division’s New Playbook on White Collar Enforcement Priorities

On May 12, 2025, the U.S. Department of Justice ("the DOJ" or "the Department") unveiled its new playbook for prosecuting white-collar and corporate crime. DOJ announced enforcement priorities for the Criminal Division ("the...more

A Vested Interest in Honest Business: California Attorney General Reminds Businesses that FCPA Violations Remain Actionable under...

On April 2, 2025, California Attorney General Rob Bonta issued a Legal Advisory reminding businesses operating in California that foreign bribery remains illegal under California law and that violations of the US Foreign...more

SEC Enforcement 2.0: Chairman Atkins Has Arrived

Paul Atkins has taken the reins of the US Securities and Exchange Commission (SEC). After being confirmed by the Senate on April 9, Atkins officially began his tenure as SEC Chairman on April 21. His arrival is expected to...more

A new sheriff in town? No time for complacency as the US pauses anti-corruption enforcement

A new anti-bribery and corruption alliance among enforcement authorities in the UK, France and Switzerland sends a clear message to corporates that any pause in enforcement of the US FCPA does not mean that acts of bribery by...more

FCPA Freeze and Refocus: Is Enforcement Becoming a Tool to Promote U.S. Economic, Foreign Policy and National Security Interests?

On February 10, 2025, President Trump signed an executive order instructing the Attorney General of the United States to pause enforcement of the Foreign Corrupt Practices Act ("FCPA") and to issue updated guidelines for...more

DOJ to Evaluate AI Risk Management and Whistleblower Protections in Corporate Compliance Programs

Over the past year, the Department of Justice ("DOJ") has warned that it will seek stiffer sentences for offenses made significantly more dangerous by the misuse of artificial intelligence ("AI") and has asked the US...more

DOJ Launches New Whistleblower Pilot Program

In March 2024, we published an alert regarding Deputy Attorney General (“DAG”) Lisa Monaco’s announcement that the US Department of Justice (“DOJ” or the “Department”) intended to design and implement a new whistleblower...more

SEC Warns Individual Actors of Potential Liability for AI-Related Security Risk Disclosure Failures

Over the past few months, the Securities and Exchange Commission (the "SEC") has issued several warnings to companies to ensure accurate disclosure of the role and risks of artificial intelligence ("AI") in their businesses....more

New Settlements Demonstrate the SEC’s Ongoing Efforts to Hold Companies Accountable for AI-Washing

In the past few months, we have published several alerts concerning the increase in regulatory attention to "AI washing," or making unfounded claims regarding artificial intelligence ("AI") capabilities.1 Senior officials at...more

DOJ Doubles Down on Warnings Against AI Misuse

In February 2024, we published an alert concerning the increase in regulatory attention to "AI washing," or making unfounded claims regarding artificial intelligence ("AI") capabilities. Notably, on February 14, 2024,...more

DOJ Announces Pilot Program to Pay Monetary Rewards to Whistleblowers

During the American Bar Association's 39th National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco announced the launch of the U.S. Department of Justice's (DOJ or the Department) pilot program to...more

Recent Regulatory Announcements Confirm Increased Scrutiny of “AI-Washing”

In December 2023, we published an alert concerning US Securities and Exchange Commission ("SEC") Chair Gary Gensler's warning to public companies against "AI washing" – that is, making unfounded claims regarding artificial...more

DOJ and FTC Update Guidance on Preservation Obligations regarding Ephemeral Messages - What Steps Should You Be Taking?

On January 26, 2024, the DOJ and FTC announced that they were updating the language in their "standard preservation letters and specifications for all second requests, voluntary access letters, and compulsory legal process,...more

Proposed EU Anti-Corruption Directive – how does it compare to the US and UK gold standard?

The European Commission has published a proposed Directive which, building on measures already in place, would require member states to incorporate uniform anti-bribery measures into their laws. Whilst most EU member states...more

The Complementary Roles of the European Public Prosecutor's Office and the European Anti-Fraud Office

In June 2021, the European Public Prosecutor's Office ("EPPO"), a body charged with investigating and prosecuting economic crimes against the financial interests of the European Union ("EU"), became the first supranational...more

In Re Boeing Decision Underscores Need for Risk-Based Corporate Governance by Directors

Following enforcement actions imposing corporate criminal or civil liability, shareholders often bring derivative actions seeking to hold directors liable for related compliance failures by alleging they breached their...more

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