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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

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

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 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

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

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

DOJ refines cooperation requirements of FCPA corporate enforcement policy

On November 20, 2019, the U.S. Department of Justice (DOJ) announced several subtle, but important, adjustments to its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. These recent changes relate to...more

ADG Insights: 2019 Bribery and corruption enforcement landscape

Through ADG Insights, we share with you the top legal and political issues affecting the aerospace, defense, and government services (ADG) industry. Our ADG industry team monitors the latest developments to help our clients...more

ADG Insights: Top Bribery and Corruption Developments of ADG Companies in 2018

Through our monthly ADG Insights series, we are pleased to share with you the top legal and political issues affecting the aerospace, defense, and government services (ADG) industry. Our ADG industry team monitors the latest...more

Top bribery and corruption developments in 2017 for ADG companies

In recent years, U.S. and Western European military spending has decreased as military spending in other parts of the world has risen. As a result, aerospace, defense and government services (ADG) companies increasingly rely...more

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