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Reshaped Priorities: Navigating Changes to FCPA and FARA Enforcement

On February 10, 2025, President Donald Trump signed an Executive Order directing the Department of Justice (DOJ) to pause enforcement of the U.S. Foreign Corrupt Practices Act (FCPA), citing concerns over the competitive...more

Expansion of Global Capability Centers Requires Anticorruption Compliance Planning

Companies looking to set up global capability centers in India should take steps at the outset to assure compliance with applicable anti-bribery and anti-corruption laws and standards. The FCPA prohibits bribing or...more

DHS’s New Criminal Enforcement Initiative to Prosecute Corporations for Forced Labor

Criminal investigations will target businesses profiting from the importation into the United States of goods made using forced labor. The new criminal enforcement initiative seeks to leverage data about corporate supply...more

Great Expectations - DOJ holds anti-corruption compliance programs to a high standard in evaluating their credibility

On February 8, 2017, the U.S. Department of Justice (DOJ) released a list of important topics and sample questions that the Criminal Division’s Fraud Section has frequently found relevant in evaluating the adequacy of a...more

New FCPA Self-Reporting Pilot Program Formalizes Rewards but Relies on Discretionary Implementation

On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more

Lacey Act Lessons from the Lumber Liquidators $13 Million Settlement: Has the Definition of “Due Care” Been Expanded?

On October 7, 2015, Lumber Liquidators agreed to plead guilty to five criminal charges, including one felony, stemming from the purchase and import of certain wood products through three separate Chinese suppliers. The plea...more

Preparing for Brazil's New Anti-Corruption Law: What In-House Counsel Should Know

Earlier this year, the Brazilian government approved a sweeping anti-corruption law known as the Brazilian Clean Companies Act ("BCCA" or "Act"), which is set to take effect on January 29, 2014. The new law provides for a...more

New FCPA Guidance Provides Insight Into Government’s View of Corporate Compliance

On November 14, 2012, the Foreign Corrupt Practices Act “Resource Guide” (the “Guidance”) was finally published, and at well over 100 pages, it constitutes a “non-binding informal summary” of various statutes, U.S. Department...more

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