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
While hospitals will no longer be formally considered sensitive locations under new immigration directives, health care facilities and providers maintain responsibility to protect access to patient care and confidentiality....more
1/27/2025
/ Data Privacy ,
Department of Homeland Security (DHS) ,
EMTALA ,
Enforcement Actions ,
Health Care Providers ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare Facilities ,
Hospitals ,
Immigration and Customs Enforcement (ICE) ,
Immigration Enforcement ,
Patient Access ,
Patient Privacy Rights
On January 9, 2024, the U.S. Court of Appeals for the Fifth Circuit reversed a 2022 jury verdict for the Commodity Futures Trading Commission ("CFTC") against EOX Holdings LLC and a former broker, Andrew Gizienski, holding...more
Each year, the Department of Justice ("DOJ"), the Securities and Exchange Commission ("SEC"), and in recent years, the Commodity Futures Trading Commission ("CFTC") dedicate substantial resources to investigating and...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)
Established in 1974 in Washington, D.C., the CFTC was originally responsible for overseeing and regulating the commodity futures and options markets in the United States. Initially, its primary focus was to regulate trading...more
9/16/2021
/ Brazil ,
CFTC ,
Commodity Exchange Act (CEA) ,
Derivatives ,
Enforcement Actions ,
Enforcement Authority ,
Foreign Exchanges ,
Futures ,
Latin America ,
Regulatory Authority ,
Regulatory Standards ,
Regulatory Violations ,
Swaps
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
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
In reaction to fallout from the recent Odebrecht scandal, and aided by shifting political winds, Peru and Argentina have enacted significant corporate anticorruption legislation. Both countries have implemented laws...more
2/28/2018
/ Anti-Corruption ,
Argentina ,
Bribery ,
Corporate Counsel ,
Corporate Criminal Fines ,
Corporate Liability ,
Corruption ,
Criminal Prosecution ,
Enforcement Actions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Odebrecht ,
OECD ,
Parent Corporation ,
Peru ,
Subsidiaries