On June 10, 2025, the Deputy Attorney General issued the highly anticipated Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) (“Guidelines”), complying with the directive in President...more
6/11/2025
/ Bribery ,
Cartels ,
Compliance ,
Corporate Counsel ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
New Guidance ,
Terrorist Organizations ,
Trump Administration
On May 12, 2025, Matthew Galeotti, the Head of the Criminal Division at the Department of Justice ("DOJ") issued a new white collar enforcement plan (“Enforcement Plan”) titled “Focus, Fairness, and Efficiency in the Fight...more
5/14/2025
/ Bribery ,
Compliance ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
Foreign Corrupt Practices Act (FCPA) enforcement activity increased overall in 2024, with a notable uptick in Department of Justice (DOJ) enforcement actions compared to 2023, despite a decrease in public Securities and...more
1/31/2025
/ Anti-Corruption ,
Compliance ,
Corporate Counsel ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Penalties ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
White Collar Crimes
On February 22, 2023, the Department of Justice (DOJ) issued a Voluntary Self-Disclosure Policy (VSDP) which, effective immediately, applies to all U.S. Attorneys’ Offices (USAOs) nationwide with respect to corporate criminal...more
On September 15, 2022, the Department of Justice (Department) released a memorandum revising several key aspects of its corporate criminal enforcement policies. The new policy, titled Further Revisions to Corporate Criminal...more
9/20/2022
/ Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Crimes ,
Corporate Culture ,
Corporate Misconduct ,
Corporate Monitoring ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Personal Liability ,
Voluntary Disclosure ,
White Collar Crimes
On July 3, 2020, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) released the second edition of the Resource Guide to the U.S. Foreign Corrupt Practices Act (2020 Guide), the first update to...more
On June 1, 2020, Assistant Attorney General for the Criminal Division, Brian A. Benczkowski, announced changes to the U.S. Department of Justice’s (“DOJ”) Evaluation of Corporate Compliance Programs (“2020 Guidance”), the...more
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more
1/18/2019
/ Anti-Bribery ,
Anti-Corruption ,
Brazil ,
Bribery ,
Chief Compliance Officers ,
China ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Investigations ,
Corruption ,
Credit Suisse ,
Criminal Investigations ,
Criminal Prosecution ,
Declination ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Panasonic ,
Petrobras ,
Securities and Exchange Commission (SEC) ,
Strategic Enforcement Plan ,
Voluntary Disclosure ,
Whistleblowers ,
Yates Memorandum
Corporate monitors have long formed part of the US government’s white-collar crime enforcement toolkit, but recent developments suggest that Department of Justice (DOJ) enthusiasm for their use may be diminishing whilst, in...more
On October 12, 2018 in remarks made at the NYU School of Law Program on Corporate Compliance and Enforcement’s Conference on Achieving Effective Compliance, Assistant Attorney General for the U.S. Department of Justice...more