On May 12, 2025, the Department of Justice Criminal Division announced significant changes to its corporate white-collar criminal enforcement priorities. In line with the Trump administration’s recalibration toward...more
The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more
3/3/2025
/ Anti-Money Laundering ,
Cartels ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Financial Services Industry ,
Justice Against Sponsors of Terrorism Act (JASTA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Terrorist Organizations ,
Trump Administration ,
U.S. Treasury
On February 10, 2025, President Donald J. Trump signed an Executive Order pausing enforcement of the Foreign Corrupt Practices Act ("FCPA") by the U.S. Department of Justice ("DOJ") for 180 days and ordering Attorney General...more
The Development: On March 7, 2024, Deputy Attorney General ("DAG") Lisa Monaco discussed updates to the Department of Justice's ("DOJ" or "Department") corporate criminal enforcement policies and announced a pilot program...more
3/14/2024
/ Artificial Intelligence ,
CFTC ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Guidance ,
Federal Pilot Programs ,
Money Laundering ,
Popular ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
The recently created SDNY Whistleblower Pilot Program encourages individuals to self-disclose certain criminal conduct and cooperate in resulting investigations and prosecutions.
...more
2/8/2024
/ Anti-Corruption ,
Corruption ,
Criminal Investigations ,
Criminal Liability ,
Department of Justice (DOJ) ,
New York ,
Non-Prosecution Agreements ,
Pilot Programs ,
Self-Disclosure Requirements ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
Foreign Corrupt Practices Act (“FCPA”) enforcement continues to slowly rebound from pre-pandemic levels. In 2023, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) resolved 13 corporate FCPA...more
In light of the DOJ’s most recent guidance on the use of personal devices and third-party messaging applications by corporate personnel, this White Paper addresses issues and challenges that companies are facing in this area...more
10/18/2023
/ CFTC ,
Compliance ,
Cybersecurity ,
Data Collection ,
Data Privacy ,
Data Protection ,
Department of Justice (DOJ) ,
Electronic Communications ,
Financial Industry Regulatory Authority (FINRA) ,
Guidance Update ,
Instant Messaging Apps ,
Mobile Devices ,
Policies and Procedures ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes ,
Workplace Communication
In Short -
The Situation: The U.S. Department of Justice ("DOJ" or "Department") and the U.S. Environmental Protection Agency ("EPA") recently announced the creation of a regional, cross-agency taskforce, targeting...more
8/7/2023
/ Biden Administration ,
Clean Air Act ,
Clean Water Act ,
Department of Justice (DOJ) ,
Environmental Crimes ,
Environmental Justice ,
Environmental Protection Agency (EPA) ,
Environmental Violations ,
Natural Resources ,
Pollution Control ,
Puerto Rico ,
Regulatory Oversight ,
Supplemental Environmental Project (SEP) Policy ,
Virgin Islands
On February 22, 2023, the U.S. Department of Justice ("DOJ" or "Department") announced the Voluntary Self-Disclosure Policy ("VSD Policy" or "Policy"), detailing the circumstances under which a company can receive credit for...more
Foreign Corrupt Practices Act (“FCPA”) enforcement has yet to rebound from the immediate pre-pandemic period. In 2022, DOJ and SEC resolved eight corporate FCPA matters for $878 million, including four resolutions coordinated...more
3/3/2023
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Bribery ,
Compliance ,
Corporate Counsel ,
Corporate Crimes ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
Securities and Exchange Commission (SEC)
As described in the first White Paper in this series on internal investigations, "Conducting an Effective Internal Investigation—An Overview," corporations are under increased scrutiny by regulators across the globe, and as a...more
With developments in the investigations field, including the ongoing expansion of this field internationally, companies face an unprecedented level of scrutiny from outside parties, including government agencies, and are...more
In Short -
The Situation: On September 15, 2022, Deputy Attorney General Lisa Monaco announced significant changes and updates to the Department of Justice's corporate criminal enforcement policies. ...more
The Department of Justice (“DOJ”) in certain circumstances requires the appointment of a corporate monitor in connection with corporate criminal resolutions. Historically, women and lawyers of color have been underrepresented...more
On June 3, 2021, President Biden issued a memorandum declaring anticorruption efforts to be "a core United States national security interest" and announcing a plan to "significantly bolster" anticorruption enforcement. While...more
6/22/2021
/ Anti-Corruption ,
Biden Administration ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Guidance ,
Financial Crimes ,
Foreign Corrupt Practices Act (FCPA) ,
Interagency Guidance ,
Money Laundering ,
National Security ,
Strategic Planning ,
White Collar Crimes
The Foreign Corrupt Practices Act ("FCPA") is a U.S. federal law from the late 1970s that prohibits covered entities and individuals from directly or indirectly paying bribes to non-U.S. government officials to obtain or...more
An uptick in fraud prosecutions and litigation has historically followed federal crisis relief programs. In addition to this historical trend, the attention fraud related to the novel coronavirus ("COVID-19") has garnered...more
10/12/2020
/ Borrowers ,
CARES Act ,
Coronavirus/COVID-19 ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Government Investigations ,
Paycheck Protection Program (PPP) ,
SBA ,
TARP
The Situation: In United States v. Hoskins, the United States Department of Justice ("DOJ") charged a foreign national who worked in France for a British subsidiary of a French company with conspiring to violate the Foreign...more