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DOJ Issues Anticipated FCPA Enforcement Guidelines with Focus on US Interests, Individual Accountability

The US Department of Justice has issued new guidance regarding enforcement of the Foreign Corrupt Practices Act (FCPA) in a June 9 memorandum from Deputy Attorney General Todd Blanche. The memorandum formalizes a shift in...more

Cartels, TCOs, ‘Instrumentalities of a Government’: Reassessing FCPA Risk Amid Shifting US Enforcement Priorities

Whether cartels do or do not qualify as “instrumentalities of a government” under current FCPA law or based on the AG’s forthcoming revised FCPA guidance, their entanglement with corrupt officials and influence over local...more

UK and European Taskforce Emerges to Expand Anti-Corruption as US Looks to Scale Back

The United Kingdom, France, and Switzerland recently issued a founding statement to establish a new anti-corruption prosecutorial taskforce—an international move that could be seen as a response to the United States’ pause on...more

Newly Confirmed AG Pam Bondi Issues Directive Limiting Scope of FCPA Enforcement

Newly Appointed US Attorney General Pam Bondi issued a directive shifting the focus of Foreign Corrupt Practices Act investigations and cases away from those that do not involve criminal operations of cartels and...more

Staying in Bounds: Compliance Considerations in the Sports Industry

In the complex and dynamic world of sports, legal compliance is crucial for maintaining integrity, ensuring fair play, and safeguarding the interests of all stakeholders. From anti-corruption measures to tax issues to...more

Despite Snyder Ruling, Gratuities Still an Issue for Government Contractors

The US Supreme Court’s June 26 ruling in Snyder v. United States clarified that the primary federal law regulating state and local corruption, 18 USC § 666, does not bar state and local officials from accepting...more

Spotting and Mitigating Anticorruption Risk Ahead of 2026 World Cup

History is rife with examples of corruption associated with major sporting events like the World Cup, which capture the attention of spectators and viewers around the globe. These events offer the chance for businesses and...more

Due Diligence, Ethics, and Compliance Considerations for Dealmakers

In recent years, the US Department of Justice (DOJ) and US Securities & Exchange Commission (SEC) have further defined their anti-corruption due diligence and disclosure expectations of acquiring companies pre- and...more

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