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 June 5, 2025, the Department of Justice (“DOJ”) directed prosecutors to prioritize compensating victims when resolving multiagency investigations involving corporate defendants. ...more
6/13/2025
/ Corporate Crimes ,
Crime Victims ,
Declination ,
Department of Justice (DOJ) ,
Government Investigations ,
Investigations ,
Non-Prosecution Agreements ,
Parallel Proceedings ,
Penalties ,
Policy Memorandums ,
Restitution ,
Settlement ,
Voluntary Disclosure ,
White Collar Crimes
Enforcement activity reached new heights in 2019. The year saw the two largest corporate resolutions in the history of the FCPA, corporate penalties paid to US enforcement agencies topped last year’s record levels, and...more
1/30/2020
/ Adoption ,
Anti-Bribery ,
Anti-Corruption ,
Arbitration ,
CFTC ,
Chief Compliance Officers ,
Civil Forfeiture ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Governance ,
Criminal Conspiracy ,
Declination ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Ericsson ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Legislative Agendas ,
New Legislation ,
Pending Litigation ,
Personal Liability ,
Popular ,
Resource Extraction ,
Restitution ,
Whistleblower Awards ,
Whistleblowers
On April 30, 2019, the Assistant Attorney General for the Criminal Division, Brian A. Benczkowski, announced an update to the Department of Justice’s (“DOJ”) 2017 guidance document entitled Evaluation of Corporate Compliance...more
5/10/2019
/ Acquisitions ,
Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Declination ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Investigations ,
Mergers ,
Policies and Procedures ,
Risk Assessment ,
Third-Party Service Provider ,
Training
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 November 29, 2017, “[d]ue to the unique issues presented in FCPA matters,” Deputy Attorney General Rod Rosenstein announced a new FCPA corporate enforcement policy published in a revision to the United States Attorneys'...more
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