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Anti-Corruption Compliance Criminal Investigations

Benesch

New FCPA Guidance Underscores Importance of Internal Compliance for Companies Doing Business Abroad

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On June 9, 2025, Todd Blanche, Deputy Attorney General for the United States Department of Justice, published guidelines for investigations and prosecutions under the Foreign Corrupt Practices Act (FCPA). These guidelines...more

Fenwick & West LLP

DOJ Unpauses FCPA Enforcement with New Limits

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On February 10, 2025, the president signed an executive order that paused investigation and enforcement of the FCPA for a period of 180 days, required the DOJ to review any existing FCPA investigation or prosecution, and to...more

Womble Bond Dickinson

Compliance Still Matters: The Future of FCPA Enforcement

Womble Bond Dickinson on

On January 20, President Trump issued an Executive Order designating certain international cartels as Foreign Terrorist Organizations (FTOs) or Specially Designated Global Terrorists (SDGTs). ...more

Latham & Watkins LLP

UK and European Considerations: President Trump Pauses FCPA Enforcement

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The executive order halts new and existing foreign bribery investigations — but enforcement risk in the UK and Europe remains. On February 10, 2025, President Trump issued an executive order titled “Pausing Foreign...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger

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Recorded at our 2024 White-Collar Symposium held in Philadelphia last month, this special episode dives into the landscape of white-collar criminal prosecution from the perspectives of Bill Baroni and Jesse Eisinger. Both...more

Mayer Brown

DOJ’s Criminal Division Updates Policy on 3 Key Topics: Artificial Intelligence, Whistleblower Programs, and Compliance Program...

Mayer Brown on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri (PDAAG), speaking at the Society of Corporate Compliance and Ethics Annual Compliance & Ethics Institute, announced three key updates to...more

The Volkov Law Group

Tracking FCPA Individual Enforcement

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While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more

Thomas Fox - Compliance Evangelist

The Foreign Corrupt Practices Handbook: Interview with the Authors

I recently spoke with the Foreign Corrupt Practices Act (FCPA) Handbook authors Robert Tarun and Peter Tomczak from Baker McKenzie for a two-part podcast episode. The depth of knowledge and experience in white-collar crime,...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the...

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In a single decade, the prosecutions of those accused of white-collar crime underwent a radical transformation. This thought-provoking episode will take you back in time to explore the DOJ's approach in the early 2000s Enron...more

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 3-the Discounted Fine

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 2, the Need for Speed

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Morrison & Foerster LLP

MoFo's 2023 FCPA Year in Review

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, our Foreign Corrupt Practices Act (FCPA) Year In Review provides quick, visual representations of key trends in FCPA enforcement over...more

The Volkov Law Group

DOJ’s Enforcement and Compliance Changes: Weighing the Pros and Cons of Voluntary Disclosures

The Volkov Law Group on

The Justice Department certainly has altered the landscape of enforcement, compliance priorities, and ultimately corporate decisions surrounding voluntary disclosure.  It has become a little bit more complicated to sort out...more

The Volkov Law Group

DOJ Outlines Aggressive White Collar Enforcement Measures and New Compliance Expectations (Part I of II)

The Volkov Law Group on

The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement.  Last week, Lisa Monaco, DOJ’s...more

The Volkov Law Group

Ericsson Settles Breach of 2019 FCPA Deferred Prosecution Agreement: Agrees to Plead Guilty, Pay $206 Million, and Extend...

The Volkov Law Group on

Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty.  In 2019, Ericsson entered...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for January 2023

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

The Volkov Law Group

DOJ Puts its New Stamp on FCPA Settlements: Unraveling the Glencore FCPA Settlement (Part II of V)

The Volkov Law Group on

The Justice Department has been promising a new, more aggressive approach to FCPA enforcement.  DOJ officials have made statements to that effect on numerous occasions.  The Biden Administration touted its elevation of the...more

The Volkov Law Group

You Win Some and You Lose Some:  DOJ’s Stumbles and Mixed Bag of Criminal Trial Results (Part I of III)

The Volkov Law Group on

Federal prosecutors know that their job – to represent the United States – is the highlight of their legal career. Speaking from experience, federal prosecutors are a privileged lot – they can announce in court they represent...more

Herbert Smith Freehills Kramer

At White Collar Crime Institute, DOJ Reiterates Focus on Individual Accountability in Corporate Crime Investigations

In their March 3, 2022, speeches to the 37th American Bar Association (ABA) National Institute on White Collar Crime, Attorney General Merrick Garland and Assistant Attorney General Kenneth Polite Jr. both emphasized the...more

Morgan Lewis

DOJ Ramping Up Fraud Enforcement Efforts: 2021 Year in Review Report

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The US Department of Justice’s Criminal Division Fraud Section released its annual Year in Review report on February 15, covering 2021. Despite ongoing aftershocks associated with the global pandemic, this year’s report...more

Guidepost Solutions LLC

With Enforcement Actions Likely to Increase in 2022, Companies Should Ask Where the Bodies are Buried

In 2022, companies are likely to see an increase in white collar and regulatory investigations and enforcement actions. Here are just a few reasons why this is likely to happen. First, in the late fall, Deputy Attorney...more

Wiley Rein LLP

Biden DOJ Stiffens Corporate Enforcement

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On October 28, 2021, Deputy Attorney General (DAG) Lisa Monaco announced sweeping policy changes to the U.S. Department of Justice’s (DOJ) corporate enforcement at the ABA’s 36th National Institute on White Collar Crime. DAG...more

Hogan Lovells

Happy Birthday! Ten takeaways as we chart the tenth birthday of the UK Bribery Act

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On 1 July 2021, the UK Bribery Act (the Act) – one of the world’s global bribery and corruption benchmark laws – turns 10. It’s been an eventful 10 years: the Serious Fraud Office (SFO), the Act’s primary enforcement agency,...more

Miller Canfield

Record Level of FCPA Enforcement in 2020 Highlights Key Risk Areas

Miller Canfield on

The year 2020 witnessed a record level of $2.78 billion in corporate fines and penalties from enforcement of the Foreign Corrupt Practices Act (FCPA) by the U.S. Department of Justice (DOJ) and the U.S. Securities and...more

Jones Day

FCPA 2020 Year in Review

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In 2020, the biggest Foreign Corrupt Practices Act (“FCPA”) headline was the record-shattering global anticorruption enforcement fines and penalties collected by foreign regulators in actions involving a coordinated FCPA...more

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