In two recent high-profile decisions, Chastain v. United States and Johnson v. United States, the U.S. Court of Appeals for the Second Circuit reversed wire fraud convictions that were based on theories resembling insider...more
On May 12, 2025, the DOJ announced a new “white-collar enforcement plan” identifying new corporate enforcement priorities and aiming to promote greater focus, fairness and efficiency in prosecuting corporate misconduct. In a...more
UPDATE: President Signs Executive Order Directing DOJ to Pause All FCPA Enforcement for 180 Days - On February 10, 2025, President Trump issued an Executive Order directing the U.S. Department of Justice (DOJ) to pause all...more
Key Points -
On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. announced revisions to the DOJ Criminal Division’s corporate enforcement policy that offer new incentives to self-disclose corporate...more
Key Points -
On September 15, 2022, Deputy AG Lisa O. Monaco released a Memorandum and provided remarks announcing several DOJ policy changes to prioritize and strengthen the Department’s prosecution of corporate crime....more
• The prosecution of individuals remains a key priority for DOJ FCPA enforcement actions.
• DOJ is “busier than ever,” focused on “higher-priority,” “bread-and-butter,” and “meat-and-potatoes” cases.
• There is no...more