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Tariff Evasion and Customs Fraud Under the Microscope: DOJ Signals Aggressive Criminal Enforcement Ahead

Given the Trump Administration’s unprecedented reliance on tariffs as a foreign policy tool and a means to protect and foster U.S. industry, the U.S. Department of Justice (DOJ) is rapidly shifting resources and enforcement...more

DOJ Hits Play: The End of the FCPA “Pause” and Return to Enforcement

On June 9, 2025, the Deputy Attorney General issued a Memorandum detailing the administration’s new FCPA guidelines for all current and future investigations and enforcement actions. According to the Head of DOJ’s Criminal...more

The European Response to DOJ’s FCPA Enforcement “Pause”

On March 20, 2025, the United Kingdom, France and Switzerland jointly announced the formation of a new International Anti-Corruption Prosecutorial Taskforce (the “Task Force”) aimed at strengthening cross-border collaboration...more

Analyzing the Attorney General’s FCPA Enforcement Shift

UPDATE: President Signs Executive Order Directing DOJ to Pause All FCPA Enforcement for 180 Days - On February 10, 2025, President Trump issued an Executive Order directing the U.S. Department of Justice (DOJ) to pause all...more

Deputy AG Announces Significant Changes to DOJ Policies Regarding Corporate Investigations

Key Points - On September 15, 2022, Deputy AG Lisa O. Monaco released a Memorandum and provided remarks announcing several DOJ policy changes to prioritize and strengthen the Department’s prosecution of corporate crime....more

DOJ Provides Additional Incentives for Voluntary Self-Disclosures of Criminal Export Controls and Sanctions Violations

• On December 13, 2019, the Department of Justice (DOJ) revised and re-issued its “Export Controls and Sanctions Policy for Business Organizations” (the “Revised Policy”) to “provide greater clarity for companies faced with a...more

UK Jury Verdict Clarifies “Adequate Procedures” Under UK Bribery Act

In an important decision given on February 21, 2018, a jury in English court proceedings has considered for the first time what “adequate procedures” should be for the purpose of a defense to the corporate offense of failing...more

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