Over the past week, the U.S. Department of Justice (“DOJ”) unsealed its first Foreign Corrupt Practices Act (“FCPA”) enforcement action and issued its first declination since the pause in FCPA enforcement mandated by...more
8/18/2025
/ Anti-Corruption ,
Bribery ,
Corporate Counsel ,
Declination ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
FCPA Corporate Enforcement Policy (CEP) ,
Foreign Corrupt Practices Act (FCPA) ,
Mexico ,
Self-Disclosure Requirements ,
Significant Transnational Criminal Organization ,
Trump Administration ,
Voluntary Disclosure
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
Enforcement activity reached new heights in 2019. The year saw the two largest corporate resolutions in the history of the FCPA, corporate penalties paid to US enforcement agencies topped last year’s record levels, and...more
1/30/2020
/ Adoption ,
Anti-Bribery ,
Anti-Corruption ,
Arbitration ,
CFTC ,
Chief Compliance Officers ,
Civil Forfeiture ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Governance ,
Criminal Conspiracy ,
Declination ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Ericsson ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Legislative Agendas ,
New Legislation ,
Pending Litigation ,
Personal Liability ,
Popular ,
Resource Extraction ,
Restitution ,
Whistleblower Awards ,
Whistleblowers
On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more
12/31/2019
/ Accounting Controls ,
Bribery ,
Chief Compliance Officers ,
Civil Monetary Penalty ,
Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Counsel ,
Corporate Culture ,
Corruption ,
Criminal Conspiracy ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Ericsson ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Jurisdiction ,
Meals-Gifts-and Entertainment Rules ,
Popular ,
Remediation ,
Securities and Exchange Commission (SEC)
On August 29, 2019, the Securities and Exchange Commission (“Commission” or “SEC”) agreed to resolve an enforcement action against Juniper Networks, Inc. (“Juniper” or the “Company”), a Silicon Valley-based cybersecurity and...more
9/4/2019
/ Bribery ,
Cease and Desist Orders ,
China ,
Civil Monetary Penalty ,
Compliance ,
Corporate Counsel ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Russia ,
Securities and Exchange Commission (SEC) ,
Subsidiaries
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
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
On August 24, 2018, the United States Court of Appeals for the Second Circuit issued a significant ruling regarding the reach of the U.S. Foreign Corrupt Practices Act (FCPA) over foreign companies and individuals in United...more
8/30/2018
/ Aiding and Abetting ,
Alstom ,
Appeals ,
Bribery ,
Conspiracies ,
Corporate Counsel ,
Criminal Conspiracy ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Popular
On July 2, 2018, the Securities and Exchange Commission (Commission or SEC) settled an enforcement action against Beam Suntory Inc. (Beam), a worldwide beverage maker and distributor, over alleged violations of the Foreign...more
The past year was consequential for FCPA enforcement in numerous respects, including blockbuster penalties, new policy initiatives, and the SEC’s first DPA with an individual for FCPA violations. In April 2016, the DOJ’s...more
2/8/2017
/ Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Statistics ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Non-Prosecution Agreements ,
Popular ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure
I. Introduction: Enforcement Trends and Priorities -
Among other significant developments, 2015 saw the U.S. Department of Justice (the “DOJ” or the “Department”) document a policy priority of holding individuals...more
2/3/2016
/ Bank of New York (BNY) Mellon ,
BHP Billiton ,
Blocking Statutes ,
Bristol-Myers Squibb ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Enforcement Statistics ,
FLIR System ,
Foreign Corrupt Practices Act (FCPA) ,
Hitachi ,
Olympics ,
Strict Liability ,
Yates Memorandum