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DOJ corporate enforcement overhaul: More declinations, fewer monitors, and FCPA enforcement still in question

On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to key corporate criminal enforcement policies. The revisions’ stated aim is to provide more clarity and certainty of outcome to companies that...more

Criminal FCPA enforcement paused. Now what?

On February 10, 2025, President Trump ordered the U.S. Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) and issue new enforcement guidelines that take into consideration U.S....more

Enforcement risks increase: DOJ and SDNY initiate self-disclosure pilot programs for individuals

In the past several years, the U.S. Department of Justice (DOJ) has been pursuing a variety of strategies to increase the number of corporate criminal prosecutions. As Assistant Attorney General Nicole Argentieri, chief of...more

No monkey business – Recent FCPA probe into wildlife trafficking in Asia

An Indiana-based contract research organization for pharmaceutical testing is being investigated by the Securities and Exchange Commission (SEC) for potential violations of the Foreign Corrupt Practices Act (FCPA). The...more

DOJ announces white collar initiatives to pursue individuals and assist victims

The American Bar Association’s annual white collar crime conference is often a favorite place for the U.S. Department of Justice to announce new policies and programs, and this year’s meeting in San Francisco was no...more

DAG Monaco announces shift in DOJ enforcement policies - Prioritizing corporate misconduct and individual accountability

On October 28, 2021, Deputy Attorney General (DAG) Lisa O. Monaco gave the keynote address at the ABA’s 36th National Institute on White Collar Crime and announced a series of changes in the Department of Justice’s (DOJ)...more

2021 Enforcement Horizon: New administration civil and criminal enforcement efforts

With a new administration comes new policies and enforcement priorities. Today, as we kickoff our new series “2021 Enforcement Horizon,” we take notice of what has already been a very active administration, and we consider...more

Individual prosecutions under the FCPA – more trials and more caselaw

This month’s analysis looks at individual prosecutions under the Foreign Corrupt Practices Act (FCPA). Prosecutions have markedly increased over the last five years, and this will better define local, regional, and...more

DOJ aims for good, not perfect: Our view of the updated corporate cooperation policy

Government attorneys now have additional discretion in False Claims Act (FCA) civil cases to award cooperation credit to a corporation that meaningfully assists the government’s investigation without necessarily identifying...more

Japan's plea bargaining system

A new plea bargaining system – offering reduced penalties to companies that report certain violations and cooperate with government investigations – will come into effect in Japan this June, reflecting an amendment to the...more

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