On June 9, 2025, the U.S. Department of Justice (DOJ) released significant new guidance outlining how it will pursue cases under the Foreign Corrupt Practices Act (FCPA), marking a reorientation in U.S. anti-bribery...more
6/30/2025
/ Anti-Corruption ,
Bribery ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Guidance ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
Multinationals ,
National Security ,
New Guidance ,
Trump Administration
On August 1, 2024, the Department of Justice’s (DOJ) Criminal Division launched a three-year Corporate Whistleblower Awards Pilot Program (the “Pilot Program”). (See Part 1 and Part 3 of this series for more information.) The...more
On May 12, DOJ’s Criminal Division head, Matthew G. Galeotti, issued a memo to all Criminal Division personnel, entitled “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime,” to “outline the Criminal...more
Share on Twitter Print Share by Email Share Back to top On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to its Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). (See...more
Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more
3/7/2025
/ Anti-Money Laundering ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Management ,
Supply Chain
On February 10 President Trump issued an Executive Order, Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security, signaling a shift in U.S. enforcement priorities regarding...more
On Monday, September 23, DOJ’s Criminal Division announced updates to its guidance for evaluating corporate compliance programs (“ECCP”). Principal Deputy Assistant Attorney General Nicole Argentieri also delivered remarks...more
9/27/2024
/ Anti-Retaliation Provisions ,
Artificial Intelligence ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Emerging Technologies ,
Incentives ,
Penalties ,
Risk Assessment ,
Risk Management ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Protection Policies ,
Whistleblowers
On Wednesday, June 26, 2024, the United States Supreme Court issued a 6–3 decision in Snyder v. United States, overturning the jury conviction of an Indiana mayor under Title 18, Section 666, of the U.S. Code for accepting...more
The international trade and regulatory environment never has been more difficult for multinational corporations to navigate. For companies that operate, source from, or sell goods, software, or services across borders, legal...more
5/25/2023
/ Anti-Corruption ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Multinationals ,
Penalties ,
Risk Assessment ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
State-Owned Enterprises
On March 3, 2023, the Department of Justice (DOJ) announced noteworthy updates to its Evaluation of Corporate Compliance Programs (ECCP) guidance. In remarks at the American Bar Association’s National Institute on White...more
On September 15, 2022, Deputy Attorney General Lisa Monaco announced significant changes to the U.S. Department of Justice’s (DOJ) approach to corporate criminal enforcement, including revised policies and an accompanying...more
On October 28, 2021, Deputy Attorney General Lisa Monaco announced three changes to the Department of Justice’s (DOJ) approach to corporate criminal enforcement. Monaco announced the changes during the Keynote Address at the...more
The unprecedented challenges created by the COVID-19 pandemic and resulting government lockdowns could strain even the most robust compliance programs. Companies have been appropriately focused on business preservation during...more
On July 3, 2020, the U.S. Department of Justice (DOJ) Criminal Division and the Securities and Exchange Commission (SEC) released the second edition of A Resource Guide to the U.S. Foreign Corrupt Practices Act (the “FCPA...more
...Think your company and its employees are beyond the reach of U.S. authorities? Maybe you don’t have U.S. operations there, or your company isn’t publicly traded on a U.S. stock exchange. Perhaps you don’t directly sell or...more
6/2/2020
/ Anti-Bribery ,
Anti-Competitive ,
Antitrust Violations ,
Business Operations ,
Conspiracies ,
Copyright ,
Department of Justice (DOJ) ,
Enforcement ,
Exports ,
Federal Trade Commission (FTC) ,
Foreign Corrupt Practices Act (FCPA) ,
Imports ,
International Trade Commission (ITC) ,
Jurisdiction ,
Office of Foreign Assets Control (OFAC) ,
Patents ,
Sherman Act ,
Trademarks
Despite the global pandemic, the federal judiciary continues to issue rulings. In the last week, two courts provided guidance about when self-disclosures to the government waive the attorney-client privilege, underscoring the...more
4/2/2020
/ Board of Directors ,
Compliance ,
Continuing Legal Education ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Data Points ,
Department of Justice (DOJ) ,
Directors ,
Ethics ,
Internal Investigations ,
Securities and Exchange Commission (SEC)
The U.S. Department of Justice (DOJ) has released updated guidance on evaluating corporate compliance programs. The Evaluation of Corporate Compliance Programs updates prior guidance that was released by DOJ in February 2017....more
On Thursday, November 29th, the U.S. Department of Justice (DOJ) announced changes to its policy known as the “Yates Memo.” That policy, established in 2015 by then-Deputy Attorney General Sally Yates, had required companies...more
On May 9, 2018, the U.S. Department of Justice (DOJ) announced a policy related to resolutions of criminal and civil corporate enforcement. The new “Policy on Coordination of Corporate Resolution Penalties” was issued by...more