On June 9, Deputy Attorney General Todd Blanche issued a memorandum entitled Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (the Memo) addressed to the head of the Criminal Division of the...more
6/13/2025
/ Anti-Corruption ,
Bribery ,
Corporate Governance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
White Collar Crimes
Two recent opinions released by the Department of Justice (DOJ) serve as a reminder that even under the strictly enforced Foreign Corrupt Practices Act (FCPA), payments to government officials are permissible in certain...more
In the past several years there has been a significant decrease in Foreign Corrupt Practices Act (FCPA) enforcement efforts. Reports suggest that corporate criminal cases have decreased by roughly 50% since 2012. FCPA...more
12/22/2022
/ Anti-Bribery ,
Books & Records ,
Corporate Crimes ,
Corporate Governance ,
Criminal Investigations ,
Criminal Penalties ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Popular ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Third-Party Risk
Since late March, the U.S. government has announced several significant enforcement actions under the Foreign Corrupt Practices Act (FCPA), the main U.S. law that prohibits bribery of non-U.S. government officials....more
There have been a relatively limited number of U.S. Foreign Corrupt Practices Act (FCPA) enforcement actions in recent years. Nonetheless, two recent announcements (one resolution, one declination) by U.S. regulators...more
In recent months, the U.S. Department of Justice (DOJ) and Securities & Exchange Commission (SEC) have announced several notable penalties for violations of the U.S. Foreign Corrupt Practices Act (FCPA). The FCPA prohibits...more
1/14/2021
/ Anti-Bribery ,
Bribery ,
Compliance ,
Corruption ,
Criminal Investigations ,
Criminal Penalties ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Deutsche Bank ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Penalties ,
Securities and Exchange Commission (SEC) ,
Securities Violations
Despite the sobering news reports on the global spread of COVID-19, companies are continuing to try to conduct operations as (relatively) normally as possible. International business is particularly affected given the...more
• A payment to a government official can take many forms.
• The SEC charges bank for books and records violation even absent a bribery charge.
• Industry-wide enforcement is a continuing tactic for U.S....more
10/24/2019
/ Accounting Controls ,
Banking Sector ,
Banks ,
Books & Records ,
Bribery ,
Enforcement Actions ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Government Officials ,
Hiring & Firing ,
Internal Controls ,
Internships ,
Quid Pro Quo ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements
• The World Bank aggressively pursues sanctions against entities and individuals for misconduct in connection with Bank-funded projects
• Sanctions can lead to cross-debarment by other multilateral development banks and...more
In a much-anticipated decision, the U.S. Court of Appeals for the Second Circuit ruled Friday that the Foreign Corrupt Practices Act (FCPA) did not apply to a foreign national acting outside the United States without direct...more
8/28/2018
/ Appeals ,
Bribery ,
Criminal Conspiracy ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Dismissals ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Interlocutory Appeals ,
Jurisdiction ,
Reversal