On July 2, 2025, the U.S. Court of Appeals for the Second Circuit ruled in United States v. Lopez that foreign commercial bribery schemes fall within the ambit of the honest services wire fraud statute, 18 U.S.C. §...more
7/11/2025
/ Appeals ,
Bribery ,
Conspiracies ,
Corruption ,
Criminal Conspiracy ,
Criminal Convictions ,
Criminal Prosecution ,
Enforcement Actions ,
Fédération Internationale de Football Association (FIFA) ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Jurisdiction ,
SCOTUS ,
Soccer ,
White Collar Crimes ,
Wire Fraud ,
World Cup
On June 10, 2025, the Deputy Attorney General issued the highly anticipated Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) (“Guidelines”), complying with the directive in President...more
6/11/2025
/ Bribery ,
Cartels ,
Compliance ,
Corporate Counsel ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
New Guidance ,
Terrorist Organizations ,
Trump Administration
On May 12, 2025, Matthew Galeotti, the Head of the Criminal Division at the Department of Justice ("DOJ") issued a new white collar enforcement plan (“Enforcement Plan”) titled “Focus, Fairness, and Efficiency in the Fight...more
5/14/2025
/ Bribery ,
Compliance ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
Anti-bribery and corruption agencies in the UK, France and Switzerland today announced a shared commitment to tackling international bribery and corruption, by way of a new taskforce intended to strengthen collaboration....more
3/21/2025
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Compliance ,
Corruption ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
Enforcement Authority ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
International Trade ,
Penalties ,
Switzerland ,
UK ,
White Collar Crimes
While Foreign Corrupt Practices Act (FCPA) enforcement activity has not come close to returning to the heights seen a few years ago, 2022 reflected significant increases from the prior year in both the number of cases against...more
2/10/2023
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
CFTC ,
Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Criminal Fines ,
Corruption ,
Cross-Border ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
On August 12, 2022, the US Court of Appeals for the Second Circuit issued another decision in a long-running criminal action that holds significant implications for the reach of the US Foreign Corrupt Practices Act (FCPA)...more
8/31/2022
/ Agents ,
Alstom ,
Anti-Bribery ,
Bribery ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Authority ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Securities and Exchange Commission (SEC) ,
Subsidiaries
In 2021, the number of publicly resolved Foreign Corrupt Practices Act (FCPA) cases was relatively low compared with previous years, but there were numerous interesting developments, and enforcement activity going forward...more
1/28/2022
/ Anti-Corruption ,
Biden Administration ,
Bribery ,
Compliance ,
Cooperation ,
Corruption ,
Cross-Border ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
As was true in many areas of the law, Foreign Corrupt Practices Act (FCPA) enforcement in 2020 - and anti-corruption enforcement more generally - was affected by the COVID-19 pandemic, but perhaps not as much as was initially...more
2/1/2021
/ Bribery ,
Compliance ,
Corporate Investigations ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Guidance ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC)
Two recent rulings in separate foreign bribery cases highlight the continued impact of individual prosecutions on the interpretation of various provisions of the Foreign Corrupt Practices Act (FCPA). In United States v....more
3/4/2020
/ Agency Relationship ,
Bribery ,
Criminal Conspiracy ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Email ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Foreign Subsidiaries ,
Indictments ,
Mail Fraud ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
Subsidiaries ,
White Collar Crimes ,
Wire Fraud
On January 31, 2020, the Department of Justice (“DOJ”) agreed to resolve allegations that Airbus SE (“Airbus”), a France-based aerospace company, used third-party business partners to bribe government officials and airline...more
2/5/2020
/ Airbus ,
Bribery ,
Civil Monetary Penalty ,
Cooperation ,
Corporate Criminal Fines ,
Corporate Fines ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
France ,
Indictments ,
ITAR ,
Remediation ,
Serious Fraud Office (SFO) ,
Settlement ,
UK ,
US Department of State ,
Voluntary Disclosure
On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more
12/31/2019
/ Accounting Controls ,
Bribery ,
Chief Compliance Officers ,
Civil Monetary Penalty ,
Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Counsel ,
Corporate Culture ,
Corruption ,
Criminal Conspiracy ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Ericsson ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Jurisdiction ,
Meals-Gifts-and Entertainment Rules ,
Popular ,
Remediation ,
Securities and Exchange Commission (SEC)
On August 29, 2019, the Securities and Exchange Commission (“Commission” or “SEC”) agreed to resolve an enforcement action against Juniper Networks, Inc. (“Juniper” or the “Company”), a Silicon Valley-based cybersecurity and...more
9/4/2019
/ Bribery ,
Cease and Desist Orders ,
China ,
Civil Monetary Penalty ,
Compliance ,
Corporate Counsel ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Russia ,
Securities and Exchange Commission (SEC) ,
Subsidiaries
This is the sixth issue of WilmerHale’s 10-in-10 Hot Topics in Energy Series. Over the course of 10 weeks, our attorneys will share insights on current and emerging issues affecting the US energy sector....more
3/8/2019
/ Brazil ,
Bribery ,
Compliance ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Ecuador ,
Energy Sector ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Mexico ,
Non-Prosecution Agreements ,
PEMEX ,
Petrobras ,
Securities and Exchange Commission (SEC)
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 August 24, 2018, the United States Court of Appeals for the Second Circuit issued a significant ruling regarding the reach of the U.S. Foreign Corrupt Practices Act (FCPA) over foreign companies and individuals in United...more
8/30/2018
/ Aiding and Abetting ,
Alstom ,
Appeals ,
Bribery ,
Conspiracies ,
Corporate Counsel ,
Criminal Conspiracy ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Popular
On August 13, 2015, a US district judge dismissed a charge seeking to hold a defendant criminally liable for conspiracy to violate the Foreign Corrupt Practices Act (FCPA) if he is not a principal or agent of a US domestic...more
8/28/2015
/ Alstom ,
Bribery ,
Criminal Conspiracy ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Foreign Official ,
Indonesia ,
Jurisdiction ,
Motions in Limine ,
UK