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DOJ Issues Anticipated FCPA Enforcement Guidelines with Focus on US Interests, Individual Accountability

The US Department of Justice has issued new guidance regarding enforcement of the Foreign Corrupt Practices Act (FCPA) in a June 9 memorandum from Deputy Attorney General Todd Blanche. The memorandum formalizes a shift in...more

Cartels, TCOs, ‘Instrumentalities of a Government’: Reassessing FCPA Risk Amid Shifting US Enforcement Priorities

Whether cartels do or do not qualify as “instrumentalities of a government” under current FCPA law or based on the AG’s forthcoming revised FCPA guidance, their entanglement with corrupt officials and influence over local...more

US Administration Tariff Expansion, Potential False Claims Act Actions, and Other Enforcement Implications

With the second Trump administration holding the reins of the executive branch, companies should brace for a renewed focus on trade enforcement. The administration has already begun to expand tariffs on a variety of items...more

Newly Confirmed AG Pam Bondi Issues Directive Limiting Scope of FCPA Enforcement

Newly Appointed US Attorney General Pam Bondi issued a directive shifting the focus of Foreign Corrupt Practices Act investigations and cases away from those that do not involve criminal operations of cartels and...more

Congress Seeks to Bolster Supply Chain Security for Federal Agencies

The US House of Representatives passed a bill on November 12, 2024 that would enhance federal efforts to implement a new supply-chain security enforcement initiative. The bipartisan bill seeks to strengthen the role and...more

Corporate Guilty Plea Indicates DOJ’s Commitment to Enforcement in Defense Industry

The US Department of Justice’s recent prosecution of Cambridge International Systems Inc. illustrates its ongoing pursuit of corporate criminal enforcement in the defense arena....more

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