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
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
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
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
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
Earlier this week, the U.S. Supreme Court resolved a circuit split among the Tenth and Eleventh Circuit Courts of Appeals by holding that because disgorgement in a Securities and Exchange Commission (SEC) enforcement action...more
6/9/2017
/ Disgorgement ,
Enforcement Actions ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Investment Management ,
Kokesh v SEC ,
Misappropriation ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Statute of Limitations ,
White Collar Crimes
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
3/10/2017
/ Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Ethics ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Internal Reporting ,
Policies and Procedures ,
Risk Assessment ,
Tone At The Top ,
Yates Memorandum
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
4/15/2016
/ Bribery ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Internal Investigations ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes ,
Yates Memorandum
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
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
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