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FCPA Un-Paused: DOJ Announces New Guidelines for FCPA Enforcement

On June 9, 2025, in a memorandum entitled Guidelines for Investigations and Enforcement of the FCPA(the “Guidelines”), the Department of Justice (DOJ) signaled that Foreign Corrupt Practices Act (FCPA) investigations and...more

Supreme Court Clarifies Scope of Federal Fraud Statutes: Deception Alone Can Support Wire Fraud Convictions

Overview - On May 22, 2025, the US Supreme Court issued a unanimous decision in Kousisis v. United States, providing clarity on the scope of the federal wire fraud statute, 18 U.S.C. § 1343. In a opinion authored by...more

DOJ Announces White-Collar Enforcement Priorities and Revised Policies

On May 12, 2025, the Criminal Division of the US Department of Justice (DOJ) issued new guidance on white-collar enforcement priorities and revised its policies on corporate voluntary self-disclosure (VSD), the selection of...more

The Future of Anti-Corruption Enforcement: Potentially Increasing State and Non-US Prosecutions as an Alternative to the FCPA

On February 10, 2025, President Donald Trump signed an executive order instructing the United States Department of Justice (“DOJ”) to pause enforcement of the Foreign Corrupt Practices Act (“FCPA”) for a period of 180 days....more

The Supreme Court Continues Its Recent Trend of Rejecting DOJ’s Broad Reading of Federal Criminal Law in Thompson v. United States

On March 21, 2025, the Supreme Court continued its push back on an expansive reading of the federal criminal laws involving fraud and corruption by overturning the false statement conviction of Patrick Daley Thompson. In a...more

US DOJ Outlines New Enforcement Priorities for Corporations and Individuals

On Wednesday, February 5, 2025, the newly confirmed Attorney General (AG) Pam Bondi issued fourteen memoranda to all Department of Justice (DOJ or the “Department”) employees regarding a wide range of new policies and...more

US DOJ Provides Details About Its Whistleblower Pilot Program in Practice and More US Attorneys’ Offices Launch Their Own Programs

On September 17, 2024, senior officials from the US Department of Justice (DOJ) gave comments offering insight into its new Corporate Whistleblower Awards Pilot Program (“Pilot Program”) as it has operated in practice so far....more

US Department of Justice Whistleblower Award Program Goes Live

On August 1, 2024, the US Department of Justice (“DOJ” or “Department”) released highly anticipated details of its new Corporate Whistleblower Awards Pilot Program (“Pilot Program”), with Principal Deputy Assistant Attorney...more

US Department of Justice Criminal Division Announces New Pilot Program Encouraging Individual Voluntary Self-Disclosures

On April 15, 2024 the Criminal Division of the US Department of Justice (“DOJ”) launched a pilot program to encourage voluntary self-disclosures by offering mandatory non-prosecution agreements (“NPAs”) to individuals who...more

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