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
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
Soon after being sworn in, President Trump issued Executive Orders identifying top administration priorities: combating illegal immigration, drug cartels, and unlawful DEI practices. Taking a similar tack, on her first day in...more
On February 22, 2023, the Department of Justice (DOJ) issued a Voluntary Self-Disclosure Policy (VSDP) which, effective immediately, applies to all U.S. Attorneys’ Offices (USAOs) nationwide with respect to corporate criminal...more
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
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
On December 6, 2021, the Biden Administration released the United States Strategy on Countering Corruption (“Strategy”), the first of its kind. This Strategy reaffirms the Biden Administration’s focus on the fight against...more
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)
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 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