On June 9, 2025, Todd Blanche, Deputy Attorney General for the United States Department of Justice, published guidelines for investigations and prosecutions under the Foreign Corrupt Practices Act (FCPA). These guidelines...more
6/13/2025
/ Anti-Corruption ,
Bribery ,
Cartels ,
Compliance ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
New Guidance ,
Significant Transnational Criminal Organization ,
Trump Administration
On May 12, 2025, Assistant Attorney General Matthew R. Galeotti, head of the U.S. Department of Justice’s Criminal Division, issued a new policy memorandum entitled “Focus, Fairness, and Efficiency in the Fight Against...more
The landscape of criminal prosecution of foreign bribery has shifted, and the second Trump administration has made its priorities clear; however, companies still have 950 million reasons and counting to strengthen their...more
3/3/2025
/ Bribery ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
False Claims Act (FCA) ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Raytheon ,
Securities and Exchange Commission (SEC) ,
Whistleblowers
On February 10, 2025, President Trump issued an Executive Order entitled Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security. The executive order comes just days after the...more
While the balance of security, privacy, and public safety has always been a concern, recent cyberattacks have highlighted conflicting guidance by United States government officials, creating potential pitfalls for businesses....more
1/8/2025
/ CFTC ,
Compliance ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Data Breach ,
Data Preservation ,
Data Privacy ,
Data Security ,
Department of Justice (DOJ) ,
Encryption ,
Enforcement ,
FBI ,
Federal Trade Commission (FTC) ,
Hackers ,
Securities and Exchange Commission (SEC) ,
Telecommunications
As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction blocking the U.S. Department of Treasury from enforcing the Corporate...more
12/31/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Time Extensions
As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction blocking the U.S. Department of Treasury from enforcing the Corporate...more
12/27/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Time Extensions
As calls for executive accountability for cybersecurity intensify, it is essential for companies to scrutinize the adequacy of ephemeral messengers, such as Signal, WhatsApp, WeChat, and Snapchat, in light of both present and...more
9/25/2024
/ Compliance ,
Cybersecurity ,
Data Privacy ,
Data Retention ,
Data Security ,
Instant Messaging Apps ,
Mobile Devices ,
Privacy Laws ,
Regulatory Oversight ,
Regulatory Requirements ,
Smart Devices ,
Snapchat ,
Social Media ,
WeChat ,
WhatsApp
In 2023, the number of federal corporate prosecutions remained far below the 25-year average after two consecutive years of increases.
..The DOJ’s Fraud Section secured just $690 million in penalties across eight...more
8/20/2024
/ Bribery ,
College Athletes ,
Colleges ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Due Diligence ,
Embezzlement ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Insider Trading ,
Name and Likeness ,
NCAA ,
Public Corruption ,
Regulatory Oversight ,
Safe Harbors ,
Sanctions ,
Title IX ,
Universities ,
Whistleblowers ,
White Collar Crimes
Since at least the adoption of the organizational Federal Sentencing Guidelines in 1991, the government has encouraged companies to adopt an effective compliance program that prevents and deters misconduct....more
5/21/2024
/ Acquisitions ,
Antitrust Violations ,
Chief Compliance Officers ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Due Diligence ,
Federal Rules of Criminal Procedure ,
Mergers ,
Safe Harbors ,
Successor Liability
We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group.
Each issue...more
4/3/2024
/ Anti-Corruption ,
Biden Administration ,
Bribery ,
Compliance ,
Corporate Misconduct ,
Corporate Transparency Act ,
Corruption ,
Criminal Convictions ,
Criminal Penalties ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Imprisonment ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Regulatory Standards ,
Securities Fraud ,
Sentencing ,
Title IX ,
Voluntary Disclosure ,
Wall Street ,
Whistleblower Awards ,
White Collar Crimes
Starting Jan. 1, 2024, the Corporate Transparency Act (CTA) will require all reporting companies to regularly disclose certain information on their beneficial owners to the U.S. Treasury’s Financial Crimes Enforcement...more