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DOJ Issues New FCPA Guidelines Amid Growing Ambitions of UK and European Prosecutors

The guidelines confirm that FCPA enforcement will continue but provide opportunities for foreign authorities to lead where US interests are not significantly impacted....more

UK and European Considerations: President Trump Pauses FCPA Enforcement

The executive order halts new and existing foreign bribery investigations — but enforcement risk in the UK and Europe remains. On February 10, 2025, President Trump issued an executive order titled “Pausing Foreign...more

Top Tips for Global Companies Preparing for the UK’s New “Failure to Prevent Fraud” Offence

Companies in the US and around the world should consider their potential for UK exposure and assess their compliance programmes in light of that risk. On 1 September 2025, the UK will implement a new corporate criminal...more

Litigation 2024 Year in Review and 2025 Outlook: A view of the landscape in Europe and the UK

Welcome to our Litigation 2024 Year in Review and 2025 Outlook. In this report, we examine the legal trends that have shaped the commercial landscape in Europe and the UK and explore how these developments are likely to...more

UK Sanctions Authority Issues Record Penalty for Russia-Related Sanctions Violations

The penalty reflects the increasingly active approach in the UK to the enforcement of sanctions breaches. The UK’s financial sanctions regulator, HM Treasury’s Office of Financial Sanctions Implementation (OFSI), has...more

Second Circuit Reinforces FCPA’s Jurisdictional Limits

Ruling holds that the government cannot use conspiracy and accomplice liability theories to reach foreign nationals that lack US ties. Key Points: ..Non-resident foreign nationals who are not otherwise subject to direct...more

Supreme Court: SEC ALJs Are Officers Subject to Constitution’s Appointments Clause

Respondents in pending or future proceedings should carefully assess their options until several key legal questions are resolved. The United States Supreme Court recently issued its ruling in Lucia v. Securities and...more

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