What in the world is happening with enforcement of the Foreign Corrupt Practices Act (FCPA)? And what does the recent executive order (EO) and Department of Justice (DOJ) guidance mean for U.S. and global companies? Our view...more
2/13/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Counsel ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Trump Administration ,
White Collar Crimes
On September 23, 2024, the Department of Justice’s (“DOJ”) Criminal Division announced significant changes to its Evaluation of Corporate Compliance Programs (“ECCP”), which prosecutors use in assessing the effectiveness of...more
10/18/2024
/ Anti-Retaliation Provisions ,
Artificial Intelligence ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Machine Learning ,
Mergers ,
Risk Management ,
Speak-up Cultures ,
Whistleblower Awards
On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...more
12/6/2023
/ Clawbacks ,
Compliance ,
Corruption ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FCPA Corporate Enforcement Policy (CEP) ,
Foreign Corrupt Practices Act (FCPA) ,
Instant Messaging Apps ,
Non-Prosecution Agreements ,
Remediation ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
White Collar Crimes
Since September 2022, the U.S. Department of Justice (“DOJ” or “the Department”) has made a number of announcements signaling notable changes to its U.S. corporate enforcement policies. These changes include key revisions to...more
On March 3, 2023, Assistant Attorney General Kenneth A. Polite announced significant revisions to the Department of Justice (“DOJ”) Criminal Division’s Evaluation of Corporate Compliance Programs (“ECCP”) specifically focused...more
3/9/2023
/ Bring Your Own Device (BYOD) ,
Compliance ,
Data Preservation ,
Department of Justice (DOJ) ,
Electronic Communications ,
Instant Messaging Apps ,
Mobile Apps ,
Regular Business Communications ,
Risk Assessment ,
Risk Management ,
WeChat ,
WhatsApp ,
Workplace Communication
Well, it was another quiet month in crypto . . . Not. We are still watching the tsunami play out in real time, as governments and the crypto market react to another seismic shift in the crypto landscape....more
12/8/2022
/ Asset Seizure ,
Bitcoin ,
Blockchain ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Convictions ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Fraud ,
NYDFS ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SDN List ,
Securities and Exchange Commission (SEC)
Since his election, President Joe Biden has loudly reaffirmed U.S. ambitions in the fight against global corruption, domestically and abroad.
Thus, in June 2021 the “Biden memorandum” declared the fight against...more
11/3/2022
/ Compliance ,
Corporate Crimes ,
Corruption ,
Department of Justice (DOJ) ,
DPA ,
Electronic Communications ,
Foreign Corporations ,
Investigations ,
Jurisdiction ,
National Security ,
Third-Party ,
WhatsApp
Greetings, and thank you for taking a look at our new monthly crypto enforcement newsletter. Our goal is to share five topics each month that we believe are of significance in the world of crypto enforcement—particularly as...more
9/7/2022
/ Anti-Money Laundering ,
CEOs ,
Certifications ,
Chief Compliance Officers ,
Chief Information Security Officer (CISO) ,
Compliance ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Enforcement ,
FinCEN ,
MSB ,
NYDFS ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Suspicious Activity Reports (SARs) ,
Virtual Currency