In response to President Trump's February 10, 2025, Executive Order pausing DOJ FCPA enforcement (the "Executive Order"), on June 9, 2025, the DOJ issued new guidelines (the "Guidelines"), which prioritize the enforcement of...more
6/18/2025
/ Anti-Corruption ,
Bribery ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Government Agencies ,
National Security ,
New Guidance ,
Regulatory Reform ,
Trump Administration
On May 12, 2025, the Department of Justice Criminal Division announced significant changes to its corporate white-collar criminal enforcement priorities. In line with the Trump administration’s recalibration toward...more
The Development: On April 15, 2024, the Department of Justice ("DOJ") Criminal Division announced a pilot program that will offer mandatory non-prosecution agreements ("NPAs") to individuals who provide original and...more
The Development: On March 7, 2024, Deputy Attorney General ("DAG") Lisa Monaco discussed updates to the Department of Justice's ("DOJ" or "Department") corporate criminal enforcement policies and announced a pilot program...more
3/14/2024
/ Artificial Intelligence ,
CFTC ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Guidance ,
Federal Pilot Programs ,
Money Laundering ,
Popular ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
The Court held that the Foreign Sovereign Immunities Act ("FSIA") does not apply to criminal prosecutions, but left open the possibility that instrumentalities of foreign states may have common law immunity from prosecution....more
In Short -
The Situation: As a follow-up to the deputy attorney general's September 2022 memorandum, the U.S. Department of Justice ("DOJ" or "Department") announced in March 2023 significant updates to its corporate...more
In Short -
The Situation: On September 15, 2022, Deputy Attorney General Lisa Monaco announced significant changes and updates to the Department of Justice's corporate criminal enforcement policies. ...more
The Biden administration took office in January 2021, announcing aggressive and sweeping anticorruption initiatives to tackle corruption around the world, labeling corruption a national security priority, and signaling a...more
1/28/2022
/ Anti-Corruption ,
Biden Administration ,
Compliance ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Securities and Exchange Commission (SEC) ,
Whistleblowers ,
White Collar Crimes
Introduction In the first 10 months of the Biden administration, senior DOJ officials have signaled a renewed focus on corporate criminal and civil enforcement against companies and individuals. ...more
On June 1st, 2o21,the European public prosecuters office, the European Union's new arm to combat fraud, became operational. The key elements of the new Public Prosecutor's Office are as follows...more
In 2020, the biggest Foreign Corrupt Practices Act (“FCPA”) headline was the record-shattering global anticorruption enforcement fines and penalties collected by foreign regulators in actions involving a coordinated FCPA...more
1/13/2021
/ Anti-Corruption ,
Biden Administration ,
Bribery ,
Compliance ,
Corporate Counsel ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
In the third year of the Trump Administration, the biggest Foreign Corrupt Practices Act ("FCPA") headlines were record corporate fines and penalties, and a banner year of individual FCPA enforcement highlighted by three DOJ...more
2/5/2020
/ Bribery ,
Compliance ,
Corporate Counsel ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Government Officials ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
The Situation: On October 8, 2019, the U.S. Department of Justice ("DOJ") announced two significant developments relating to the enforcement of white-collar crime: (i) new guidance on how prosecutors should evaluate requests...more
10/14/2019
/ Corporate Counsel ,
Corporate Crimes ,
Corporate Criminal Fines ,
Corporate Misconduct ,
Criminal Penalties ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Failure To Pay ,
Federal Sentencing Guidelines ,
New Guidance ,
White Collar Crimes
On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more
3/2/2017
/ Anti-Corruption ,
Board of Directors ,
Compliance ,
Confidential Communications ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Internal Investigations ,
New Guidance ,
OECD ,
Policies and Procedures ,
Popular ,
Publicly-Traded Companies ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Senior Managers ,
Third-Party Relationships ,
Training