U.S. Department of Justice (DOJ) Deputy Attorney General Todd Blanche issued a memorandum on June 9 (the Memo), announcing DOJ will resume enforcement of the Foreign Corrupt Practices Act (FCPA) after its brief hiatus....more
6/13/2025
/ Anti-Corruption ,
Cartels ,
Compliance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Extortion ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Popular ,
Significant Transnational Criminal Organization ,
White Collar Crimes
On May 12, 2025, Matthew Galeotti, Head of the Department of Justice’s (DOJ) Criminal Division, unveiled a comprehensive white collar enforcement strategy titled “Focus, Fairness, and Efficiency in the Fight Against...more
5/19/2025
/ Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
This shift in FCPA enforcement priorities is the latest move by the administration in its all-out war against cartels and TCOs that pose a threat to U.S. national security and its stated America First agenda. Additionally,...more
2/13/2025
/ Anti-Corruption ,
Bribery ,
Cartels ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Significant Transnational Criminal Organization ,
Statute of Limitations ,
Trump Administration
There was a flurry of DOJ whistleblower program activity over the last two weeks as the U.S. Attorneys’ Offices for the Eastern District of New York (EDNY Program), District of New Jersey (DNJ Program), Southern District of...more
9/26/2024
/ Cooperation ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Financial Fraud ,
Non-Prosecution Agreements ,
Pilot Programs ,
Public Corruption ,
Risk Management ,
Securities Violations ,
U.S. Attorney ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
DOJ has introduced the new three-year Pilot Program, managed by the Criminal Division’s Money Laundering and Asset Recovery Section, effective August 1. Under this Pilot Program, whistleblowers meeting certain criteria may be...more
8/9/2024
/ CFTC ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
FinCEN ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
Building on the recent passage of the Foreign Extortion Prevention Act (FEPA), at the American Bar Association’s 2024 National Institute on White Collar Crime conference in San Francisco earlier this month (2024 ABA...more
3/19/2024
/ American Bar Association (ABA) ,
Anti-Corruption ,
Bribery ,
Cooperation ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Fraud ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
Employers should check their confidentiality and severance agreements for a common oversight that, for some, is becoming a costly error.
Recent enforcement activity by the Securities and Exchange Commission (SEC) of Rule...more
1/23/2024
/ Compliance ,
Compliance Manuals ,
Confidentiality Agreements ,
Contract Terms ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Employee Handbooks ,
Employer Liability Issues ,
Employment Contract ,
Enforcement Actions ,
IRS ,
Non-Disparagement Provisions ,
Rule 21F-17 ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Settlement Agreements ,
Severance Agreements ,
Whistleblower Protection Policies ,
Whistleblowers
The newly announced whistleblower policy gives certain individuals who promptly and completely cooperate with prosecutors the opportunity to receive a non-prosecution agreement in exchange for their information....more
On Wednesday, March 1 the Department of Justice (DOJ) announced its first-ever prosecution of an individual for insider trading based on an executive’s use of 10b5-1 trading plans. Terren Peizer, the executive chairman of...more
3/8/2023
/ 10b5-1 Plans ,
Amended Regulation ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Enforcement Actions ,
Form 8-K ,
Indictments ,
Insider Information ,
Insider Trading ,
Popular ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Fraud
Monaco’s and Polite’s remarks, and the DOJ’s new policies and guidance, come amid the Department’s increasingly tough on corporate crime approach and emphasis on rewarding companies that have effective compliance programs...more
3/7/2023
/ Chief Compliance Officers ,
Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Crimes ,
Corporate Culture ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Electronic Communications ,
Enforcement Priorities ,
Executive Compensation ,
Monaco Memo ,
Self-Disclosure Requirements
In prepared remarks delivered at New York University School of Law on Sept. 15, Deputy AG Monaco announced significant updates to the DOJ’s corporate criminal enforcement policies.
Deputy AG Monaco’s announcement...more
9/21/2022
/ Compliance ,
Compliance Monitoring ,
Corporate Crimes ,
Corporate Culture ,
Corporate Misconduct ,
Corporate Monitoring ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Personal Liability ,
Voluntary Disclosure ,
White Collar Crimes
On August 14, 2020, the Department of Justice (the “DOJ”) issued its first Foreign Corrupt Practices Act (the “FCPA”) advisory opinion in almost six years....more
On the eve of the July 4th holiday, the Criminal Division of the Department of Justice (the “DOJ”) and the Enforcement Division of the Securities and Exchange Commission (the “SEC”) quietly published the second edition of the...more
On August 24, 2018, nearly 18 months after hearing oral argument, the U.S. Court of Appeals for the Second Circuit issued a decision in United States v. Hoskins, that significantly limits the Department of Justice’s (“DOJ”)...more
2017 marked the fortieth anniversary of the Foreign Corrupt Practices Act (FCPA), and showed continued robust enforcement against both individuals and companies by the U.S. Department of Justice (DOJ) and the U.S. Securities...more
3/9/2018
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Counsel ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
On November 29, 2017, Deputy Attorney General Rod Rosenstein expanded upon the Department of Justice’s (“DOJ”) long-running efforts to encourage companies to self-disclose Foreign Corrupt Practices Act (“FCPA”) violations by...more
The first half of 2017 has been eagerly anticipated following the record-setting year in 2016 for Foreign Corrupt Practices Act (“FCPA”) enforcement by both the U.S. Department of Justice (“DOJ”) and the U.S. Securities and...more
8/29/2017
/ Bribery ,
Compliance ,
Corruption ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Government Officials ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
White Collar Crimes
2016 was a record-setting year for Foreign Corrupt Practices Act (“FCPA”) enforcement, as both the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) recovered well over $2 billion in...more
1/26/2017
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Corporate Counsel ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
Both the United States Department of Justice (DOJ) and the United States Securities and Exchange Commission (SEC) have continued their focus on anticorruption enforcement in 2015. Although there was a decline in enforcement...more
4/20/2016
/ Corporate Fraud ,
Corruption ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Settlement ,
White Collar Crimes ,
Yates Memorandum
Pursuing a classic “carrot and stick” approach to incentivizing corporate self-disclosure of FCPA violations and individual wrongdoing connected to FCPA violations, the Department of Justice (DOJ) Fraud Section announced a...more
The investigation and prosecution of tax evasion has, in the past decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the international community. Financial institutions,...more
Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more
10/14/2015
/ Aerospace ,
Africa ,
Angola ,
Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Avon ,
BHP Billiton ,
Brazil ,
Bribery ,
China ,
Clean Companies Act ,
Compliance ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Derivative Suit ,
DPA ,
Eli Lilly ,
Enforcement Actions ,
Federal Contractors ,
Federal Prosecutors ,
Fokker ,
Football ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Goodyear ,
Hospitality Programs ,
India ,
Indictments ,
Medicaid ,
Medicare ,
Money Laundering ,
Olympics ,
PBSJ Corporation ,
PetroTiger ,
Popular ,
Public Utility ,
Racketeering ,
Russia ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Serious Fraud Office (SFO) ,
Settlement ,
Soccer ,
Sports ,
State-Owned Enterprises ,
Subject Matter Jurisdiction ,
UK Bribery Act ,
Wal-Mart ,
Whistleblowers ,
White Collar Crimes ,
Wire Fraud ,
World Cup
In 2014, a record-setting year for Foreign Corrupt Practices Act (FCPA) enforcement, the Department of Justice (DOJ) announced the largest-ever DOJ FCPA resolution—an over $772 million criminal fine for French power company...more
Over the course of 2014, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) have continued their aggressive enforcement of the Foreign Corrupt Practices Act (“FCPA”). This has led to critical...more
The first half of 2014 has seen several important developments in the enforcement of the Foreign Corrupt Practices Act (“FCPA”) as well as other anti-corruption laws worldwide. The FCPA has been in existence for more than 35...more