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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

Sovereign Wealth Funds and the FCPA: The Importance of Targeted Due Diligence

Given the global nature of sovereign wealth funds’ (SWFs’) investments and operations, it is essential that SWFs are aware of and in compliance with the Foreign Corrupt Practices Act (FCPA) in order to facilitate business...more

US Department of Justice Releases Fraud Section Year in Review for 2022

The US Department of Justice Criminal Division’s Fraud Section (DOJ) recently released its annual Year in Review report, detailing the Fraud Section’s accomplishments in 2022. Consistent with stated DOJ policy, the Fraud...more

DOJ Criminal Division’s Corporate Enforcement Policy: Is 2023 the Year of the Carrot?

The US Department of Justice (DOJ) continues to try to dispel lingering skepticism over the benefits of corporate disclosure and cooperation. In remarks delivered on January 17, Assistant Attorney General (AAG) Kenneth A....more

DOJ Deputy Attorney General Announces Changes to Corporate Crime Policy

Deputy Attorney General Lisa Monaco on September 15 announced significant updates to the US Department of Justice’s corporate criminal enforcement policies during a speech at New York University Law School. Monaco’s speech...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

DOJ Ramping Up Fraud Enforcement Efforts: 2021 Year in Review Report

The US Department of Justice’s Criminal Division Fraud Section released its annual Year in Review report on February 15, covering 2021. Despite ongoing aftershocks associated with the global pandemic, this year’s report...more

DOJ Discusses Enforcement, Reiterates Biden-Harris Anti-Corruption Commitment at ACI FCPA Conference

This LawFlash summarizes key takeaways from the American Conference Institute’s (ACI’s) 38th International Conference on the Foreign Corrupt Practices Act (FCPA), where top government officials offered insight and...more

Enforcement Issues and Trends Affecting the US Automotive and Mobility Industry

As the automotive and mobility industry continues to grow under the watch of a new US presidential administration, it is important for key players to better understand the government agencies charged with enforcing the rules...more

A Fraud Section Year in Review for a Year Like No Other

The US Department of Justice’s Criminal Division Fraud Section (DOJ) released its annual Year in Review report on February 24, covering 2020. This year’s report highlights DOJ’s sustained aggressive enforcement efforts...more

The Outlook for Enforcement Actions Under a Biden Administration

There was a perception in 2017 when then President-elect Trump took office that white collar enforcement actions under the US Department of Justice (DOJ) might drop dramatically. Many expected the Republican administration to...more

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