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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

DOJ Signals Reinvigorated Corporate Enforcement for White Collar Crime

After four years of decreased white collar enforcement activity, the Biden DOJ has announced several key policy changes designed to crack down on corporate misconduct: What companies need to know and how they can...more

Prohibited Campaign Contributions Threaten to Put Corporate Donors Behind Bars

Historic spending on the 2020 election is driving aggressive DOJ prosecution of criminal campaign finance violations. The DOJ is increasing its efforts to prosecute businesses and executives for criminal violations of the...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

Prosecuting Corporations that Benefit Financially from Human Trafficking

As forced labor and sex trafficking prosecutions steadily increase, corporations may be exposed to criminal and civil corporate liability. The U.S. Department of Justice and state law enforcement are expected to...more

DOJ to Coordinate FCPA Enforcement With Foreign Law Enforcement Agencies

New policy seeks to reduce the burden of navigating anti-corruption investigations and enforcement actions by multiple authorities. The new DOJ policy seeks to increase coordination on FCPA and related anti-corruption...more

The Future of FCPA Enforcement After Kokesh

Increased international cooperation, more aggressive investigations and greater focus on individual accountability. In light of the U.S. Supreme Court’s decision in Kokesh v. SEC, the SEC is expected to prioritize quicker,...more

DOJ’s Antitrust Fashion Show - Awaiting a price-fixing investigation in the U.S. modeling industry?

As the United Kingdom’s Competition and Markets Authority (CMA), Italy’s Autorità Garante della Concorrenza e del Mercato and France’s Autorité de la Concurrence are wrapping up their prosecutions of Europe’s top modeling...more

A “Change of Heart” in a Health Care Fraud Prosecution - Inconsistent angiogram interpretations establish reasonable doubt in...

On March 7, 2017, the U.S. District Court for the Eastern District of Kentucky reversed the October 27, 2016 criminal jury verdict against Kentucky cardiologist Dr. Richard E. Paulus, and acquitted him on all counts of health...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

Hong Kong & Singapore: Awaiting a New DOJ Tax Program for Asian Banks?

As the Department of Justice is wrapping up its prosecution of over a dozen Swiss banks, federal prosecutors and IRS special agents are analyzing a treasure trove of previously undeclared taxpayer account information that...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

The “Panama Papers” and the Secret World of Shell Corporations - Reducing Liability Exposure and Seeking Insurance Coverage

A leak of 11.5 million documents from a law firm in Panama may implicate politicians, criminals, and celebrities in sheltering of fortunes in offshore tax havens through the use of shell companies. Called the “Panama Papers,”...more

DOJ’s New White-Collar Policy Directs Prosecutors to Focus on Individual Accountability

On September 9, 2015, Deputy Attorney General Sally Quillian Yates introduced a new policy aimed at aggressively prosecuting individuals for white-collar crimes. A product of a DOJ working group that started under former...more

The Announcement of Criminal Charges against Lumber Liquidators Underscores the Need for Lacey Act Compliance

On Wednesday, April 29, 2015, Lumber Liquidators announced in its most recent 10Q that the United States Department of Justice plans to pursue criminal charges surrounding allegations the company illegally imported wood in...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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