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Imports and the False Claims Act: Recent Ninth Circuit decision reflects trends in increased import fraud enforcement and...

The Ninth Circuit’s recent decision in Island Industries Inc. v. Sigma Corporation, coupled with recent government pronouncements concerning trade enforcement, are likely to drive an increase in customs fraud FCA...more

DOJ Civil Division Assistant Attorney General’s first day memorandum sets out FCA enforcement priorities aligned with Trump...

On the day he was sworn in, June 11, 2025, Civil Division Assistant Attorney General (AAG) Brett Shumate took the unusual step of issuing a memorandum to all employees of the Department of Justice (DOJ) Civil Division – most...more

FCPA reloaded: The DOJ “unpauses” enforcement – But is it a new level?

On June 9, 2025, Deputy Attorney General Todd Blanche issued revised enforcement guidelines for the Foreign Corrupt Practices Act (FCPA), officially ending the FCPA enforcement pause that Executive Order 14209 (EO) instituted...more

Deputy Attorney General launches Civil Rights Fraud Initiative to pursue FCA cases based on alleged discrimination

On May 19, 2025, Deputy Attorney General Todd Blanche issued a memorandum (Blanche Memorandum) directing the Department of Justice’s Civil Division Fraud Section and Civil Rights Division to lead a Civil Rights Fraud...more

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

The new enforcement avengers? The UK, France, and Switzerland enforcement Taskforce: Local regulators join forces against global...

The United Kingdom (UK), France, and Switzerland announced on 20 March 2025 that they have jointly launched the International Anti-Corruption Prosecutorial Taskforce to combat complex international white-collar crime. The...more

DEI executive order compliance checklist

Since his inauguration in January, President Trump has signed multiple executive orders addressing diversity, equity, and inclusion (DEI) policies across the country. These actions have significant implications, including for...more

Executive Orders targeting DEI partially blocked by court

On February 21, a federal court in Maryland preliminarily enjoined three components of Executive Order (EO) 14151 (Ending Radical and Wasteful Government DEI Programs and Preferencing) and Executive Order 14173 (Ending...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

Global Bribery and Corruption Outlook 2025

As we welcome 2025, the year ahead promises to be a year of change. After more than 70 national elections in 2024, the dust hasn’t fully settled, not least in the United States, where President Trump has taken office for the...more

Executive Order seeks to impose FCA liability for contractor and grantee DEI programs

On January 21, 2025, President Trump issued an Executive Order titled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” (EO 14173). In commentary published since then, Hogan Lovells has analyzed various...more

Trump Executive Order targets private-sector DEI policies and practices

After assuming office, the Trump administration acted swiftly to roll back allegedly illegal diversity, equity, and inclusion (DEI) policies. On January 21, 2025, President Trump signed an Executive Order titled “Ending...more

Past is Prologue? DOJ Enforcement under POTUS 47

On 21 November 2024, hot off a political comeback for the history books, president-elect Donald Trump announced former Florida attorney general Pam Bondi as his nominee for Attorney General. The announcement followed the...more

Key insights from the 2024 ABA White Collar Conference

The 2024 American Bar Association White Collar Crime conference delivered crucial insights from artificial intelligence’s tantalizing promise to its looming threats, a focus on individual accountability, repercussions for...more

Key takeaways from the 40th ACI International Conference on the FCPA

Last week at the 40th American Conference Institute (ACI) International Conference on the FCPA, government enforcement agencies such as the Department of Justice (DOJ), Securities and Exchange Commission (SEC), and UK Serious...more

The DOJ issues rare Opinion Release on foreign government official travel

The Department of Justice (DOJ) recently issued a rare FCPA Opinion Procedure Release concerning travel of foreign government officials. Our lawyers analyze the opinion and highlight key considerations for companies engaged...more

You want what back? Key takeaways from DOJ on compensation clawbacks and compliance programs

On September 15, 2022, Deputy Attorney General Lisa Monaco released a memorandum titled “Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group,” known...more

Stericycle DPA signals more aggressive use of independent compliance monitors

On April 20, 2022, the U.S. Department of Justice (DOJ) announced it had entered a three-year deferred prosecution agreement (DPA) with Stericycle Inc. to resolve allegations that it violated the Foreign Corrupt Practices Act...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

[Webinar] Lights, camera, action! Internal investigations in media and entertainment - November 5th, 11:00 am - 12:00 pm PDT

Please join us on November 5 for a dynamic CLE discussion to navigate internal investigations across the media and entertainment industries. The program will keep you engaged with perspectives from across our Labor &...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

Joint focus by Biden Administration and Congress points towards enhanced anti-corruption efforts

There has been significant movement recently, by both the Biden Administration as well as Congress, to enhance the U.S. government’s ability to tackle corruption. This article provides a summary of those efforts and several...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

UK SFO Publishes DPA Guidance: comparing and contrasting the approach of the U.S. DOJ to DPAs

The United Kingdom Serious Fraud Office (SFO) recently published comprehensive guidance on Deferred Prosecution Agreements (DPAs). Lisa Osofsky, Director of the SFO, stated, “Over the past six years, we at SFO have been...more

Protecting attorney work product in internal investigations: A cautionary tale

On May 1, 2020, the D.C. Circuit denied RPM International’s petition for a writ of mandamus to vacate a district court order compelling disclosure of interview memoranda prepared by outside counsel to the Securities and...more

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