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President Trump Pauses DOJ FCPA Enforcement and Orders Preparation of New Enforcement Guidelines

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

FCPA 2023 Year in Review

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

FCPA 2022 Year in Review

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

DOJ Announces Major Changes to Corporate Criminal Enforcement Policies

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

President Biden Declares Anticorruption Efforts a Core U.S. National Security Interest

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

Recent FCPA Developments for Latin America

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

Second Circuit Rejects DOJ's Attempt to Expand Reach of the FCPA

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

Peru and Argentina: New Bribe Regimes Put Companies at Risk

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

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