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 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
Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more
1/31/2024
/ Acquisitions ,
Anti-Bribery ,
Anti-Corruption ,
Clawbacks ,
Compliance ,
Cooperation ,
Data Protection ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Enforcement Guidance ,
Enforcement Priorities ,
Enforcement Statistics ,
Executive Compensation ,
FCPA Corporate Enforcement Policy (CEP) ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Latin America ,
Mergers ,
Pilot Programs ,
Safe Harbors ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Voluntary Disclosure
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 January 31, 2020, the Department of Justice (“DOJ”) agreed to resolve allegations that Airbus SE (“Airbus”), a France-based aerospace company, used third-party business partners to bribe government officials and airline...more
2/5/2020
/ Airbus ,
Bribery ,
Civil Monetary Penalty ,
Cooperation ,
Corporate Criminal Fines ,
Corporate Fines ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
France ,
Indictments ,
ITAR ,
Remediation ,
Serious Fraud Office (SFO) ,
Settlement ,
UK ,
US Department of State ,
Voluntary Disclosure
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 April 5, 2016, the U.S. Department of Justice released a nine-page memorandum launching a one-year pilot program to reward companies that voluntarily self-report violations of the Foreign Corrupt Practices Act.
Now...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
On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more
4/11/2016
/ Compliance ,
Cooperation ,
Corporate Misconduct ,
Corruption ,
Criminal Prosecution ,
Declination ,
Department of Justice (DOJ) ,
Disgorgement ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes