On June 9, 2025, the Deputy Attorney General issued a Memorandum detailing the administration’s new FCPA guidelines for all current and future investigations and enforcement actions. According to the Head of DOJ’s Criminal...more
On May 12, 2025, the DOJ announced a new “white-collar enforcement plan” identifying new corporate enforcement priorities and aiming to promote greater focus, fairness and efficiency in prosecuting corporate misconduct. In a...more
On March 20, 2025, the United Kingdom, France and Switzerland jointly announced the formation of a new International Anti-Corruption Prosecutorial Taskforce (the “Task Force”) aimed at strengthening cross-border collaboration...more
5/13/2025
/ Anti-Corruption ,
Corporate Counsel ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Government Agencies ,
Switzerland ,
UK
UPDATE: President Signs Executive Order Directing DOJ to Pause All FCPA Enforcement for 180 Days - On February 10, 2025, President Trump issued an Executive Order directing the U.S. Department of Justice (DOJ) to pause all...more
Executive Summary -
- On March 7, 2024, the NSD of the DOJ issued an updated NSD Enforcement Policy to include a new section covering VSDs in connection with mergers and acquisitions.
- These updates follow repeated...more
3/19/2024
/ Acquisitions ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
Mergers ,
National Security ,
Policies and Procedures ,
Regulatory Reform ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers
Key Points -
On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more
4/18/2023
/ Compliance ,
Corporate Counsel ,
Corporate Culture ,
Corporate Misconduct ,
Economic Sanctions ,
Enforcement Actions ,
Financial Transactions ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Wells Fargo
Key Points -
The DOJ recently announced several policy updates tethering resolution of criminal investigations to a company’s compensation and bonus programs.
These updates include executive compensation focused...more
Key Points -
On March 2, 2023, DOJ announced that its NSD would hire more than 25 new prosecutors to investigate and prosecute sanctions evasion, export controls violations and similar economic crimes. Consistent with...more
The New Year Brings a New Enforcement Focus on Emerging Technology -
In 2021, newly confirmed members of the Biden administration set the stage for increased enforcement activity, surging resources to investigations and...more