On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the “Blanche Memorandum”) detailing new guidelines for the Department of Justice’s approach to investigating and enforcing the Foreign Corrupt...more
We have previously written about the impact of the pause in enforcement of the FCPA implemented by the Trump Administration on non-American companies.1 Although the 180-day review period the Executive Order provided to the...more
4/29/2025
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
EU ,
Foreign Corrupt Practices Act (FCPA) ,
Popular ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
UK
The State Department’s February 20, 2025, designation of specific Mexican drug cartels and Transnational Criminal Organizations (TCOs) as foreign terrorist organizations (FTOs) creates serious new risks for businesses...more
3/12/2025
/ Anti-Terrorism Financing ,
Cartels ,
Corporate Counsel ,
Corporate Crimes ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Florida ,
Mexico ,
National Security ,
New Jersey ,
Risk Management ,
Texas
This summary is part of our regular reporting of trends and developments related to investigations and enforcement activity into fraud, corruption, and other misconduct by authorities in the United States and the Americas and...more
8/9/2021
/ Anti-Corruption ,
Austria ,
Banks ,
Biden Administration ,
Brazil ,
Bribery ,
DEA ,
Department of Justice (DOJ) ,
Enforcement Actions ,
EU ,
FBI ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Guatemala ,
Investigations ,
Latin America ,
Mexico ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
UK
In the fourth quarter of 2019, U.S. enforcement authorities sustained efforts to prosecute individuals violating U.S. anticorruption laws in matters related to Latin America, while authorities in Latin America, including in...more
1/22/2020
/ Anti-Corruption ,
Asset Seizure ,
Brazil ,
Bribery ,
Corruption ,
Criminal Convictions ,
Criminal Investigations ,
Criminal Liability ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Enforcement Authority ,
Export Controls ,
Financial Crimes ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Guilty Pleas ,
Legislative Vetoes ,
Mexico ,
Peru ,
Sanction Violations ,
Statutory Authority ,
Voluntary Disclosure
Major FCPA Enforcement Action -
Including charges against the CEO and CFO for failing to prevent misconduct -
In one of the largest FCPA settlements in history, hedge fund Och-Ziff Capital Management Group LLC...more
12/23/2016
/ CEOs ,
Democratic Republic of Congo ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Hedge Funds ,
Japan ,
Libya ,
Och-Ziff ,
Penalties ,
Securities and Exchange Commission (SEC) ,
Settlement
In one of the largest FCPA settlements in history, hedge fund Och-Ziff Capital Management Group LLC (“Och-Ziff”) recently resolved a long-running government inquiry by agreeing to $413 million in financial penalties and a...more
10/10/2016
/ Africa ,
Bribery ,
Deferred Prosecution Agreements ,
Democratic Republic of Congo ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Hedge Funds ,
Internal Controls ,
Investment ,
Libya ,
Och-Ziff ,
Popular ,
Private Equity Funds ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
Sovereign Wealth Funds