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New DOJ FCPA Guidelines Target Cases Linked to US Strategic Interests

On June 9, U.S. Deputy Attorney General Todd Blanche issued a memorandum entitled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA),” which establishes guidelines to ensure that FCPA...more

Anti-Money Laundering Enforcement Risk Still Remains for Virtual Asset Services Providers

Despite the Trump administration’s generally favorable stance toward cryptocurrency and blockchain innovation, virtual asset services providers (VASPs) must remain vigilant in complying with anti-money laundering (AML)...more

Keep Calm and Carry On: Thoughts on Recent Orders on FCPA Enforcement

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

A Commitment to Transparency: Clarifying Key Enhancements to the U.S. Department of Justice’s Corporate Enforcement Guidance

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

Bigger Carrots, More Sticks? DOJ Revises Its Corporate Criminal Enforcement Policy

On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. (“AAG Polite”) announced several key revisions to the Department of Justice (“DOJ”) Criminal Division’s Corporate Enforcement Policy (the “CEP”) governing...more

Top PHive Crypto Enforcement Notes: December Edition

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

Top PHive Crypto Enforcement Notes: November Edition

It certainly feels like a race between innovation and enforcement these days, with regulators and law enforcement stepping up the cautionary rhetoric and promising broader enforcement aimed at corporate actors....more

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