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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

DOJ Revises Corporate Monitor Policy with New Cost and Oversight Rules

On May 12, 2025, the US Department of Justice’s Criminal Division published a set of memoranda outlining white collar enforcement priorities and an updated outlook on the imposition and selection of corporate monitors. The...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

CFTC Enforcement Replaces Previous Cooperation Guidance With New Mitigation Credit Matrix

The Division of Enforcement of the US Commodity Futures Trading Commission (CFTC or Commission) recently issued an advisory revoking prior guidance for its staff in recommending enforcement resolutions (the Advisory) and...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

US Department of Justice Updates Its Evaluation of Corporate Compliance Programs

The Criminal Division of the US Department of Justice released a revised version of its Evaluation of Corporate Compliance Programs on September 23, 2024. The guidance is intended to help prosecutors assess the effectiveness...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

DOJ Criminal Division Launches Corporate Whistleblower Awards Pilot Program

The US Department of Justice’s (DOJ) Criminal Division on August 1 announced the details of its much-anticipated Corporate Whistleblower Awards Pilot Program. This three-year initiative aims to incentivize individuals to...more

Corporate Guilty Plea Indicates DOJ’s Commitment to Enforcement in Defense Industry

The US Department of Justice’s recent prosecution of Cambridge International Systems Inc. illustrates its ongoing pursuit of corporate criminal enforcement in the defense arena....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

DOJ Releases 2023 Fraud Section Year in Review

In recent weeks, the US Department of Justice (DOJ) Criminal Division’s Fraud Section released its annual Year in Review report, summarizing the Fraud Section’s accomplishments in 2023. This detailed account points to a...more

Forced Labor Laws Year in Review

In 2023, there was an expansion in scope of the discussion around forced labor in the global supply chain. In the United States, the enforcement of the Uyghur Forced Labor Prevention Act (UFLPA) continued to be the main...more

CFTC Releases New Blueprint for Enforcement: Higher Penalties, Monitors, Admissions

The Division of Enforcement of the US Commodity Futures Trading Commission (CFTC or Commission) published on October 17, 2023 an advisory to assist its staff in recommending future enforcement resolutions to the Commission...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 Attorneys Emphasize Benefits of New Voluntary Self-Disclosure Policy

Assistant Attorney General (AAG) Kenneth A. Polite Jr. of the US Department of Justice’s (DOJ’s) Criminal Division recently joined several high-profile, diverse US Attorneys at the inaugural Charlotte E. Ray Lecture and White...more

DOJ Announces Compensation Clawback Pilot Program, Changes to Corporate Compliance Program Evaluation Criteria

The US Department of Justice recently announced a compensation clawback pilot program as well as changes to the corporate compliance program evaluation criteria in the latest of a flurry of policy updates....more

Responsible Labor Report: 2022–2023

The prevention of forced labor in the global supply chain has been elevated in visibility and consequence over the last several years. In 2022, the emphasis focused largely, though not exclusively, on trade remedies. The...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

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