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Anti-Corruption Criminal Investigations Enforcement Actions

Nossaman LLP

DOJ Issues New FCPA Enforcement Guidelines

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New factors for investigating and enforcing the Foreign Corrupt Practices Act were recently released by head of the Criminal Division of the U.S. Department of Justice (DOJ) in, “Guidelines for Investigations and Enforcement...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

Baker Botts L.L.P.

Back from the Dead? Takeaways from US DOJ’s New Guidelines for FCPA Investigations and Enforcement

Baker Botts L.L.P. on

On June 9, 2025, the Deputy Attorney General of the United States Department of Justice issued “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (the “Memorandum”). The Memorandum...more

Cozen O'Connor

DOJ Restarts Enforcement of Foreign Corrupt Practices Act, Focusing on U.S. Interests

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On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum titled "Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)." The memo follows a four-month review triggered by...more

Skadden, Arps, Slate, Meagher & Flom LLP

Khouri: Is UK-US Extradition on Its Way to Becoming an Ex-Tradition?

On 12 February 2025, the UK Supreme Court handed down its decision in El-Khouri v Government of the United States of America (El-Khouri), declining to extradite Joseph El-Khouri to the US. The ruling marks a pivotal moment in...more

Womble Bond Dickinson

Compliance Still Matters: The Future of FCPA Enforcement

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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

Troutman Pepper Locke

Key Considerations After DOJ Announces Shifting Enforcement Priorities

Troutman Pepper Locke on

On February 5, U.S. Attorney General (AG) Pam Bondi issued 14 memoranda to Department of Justice (DOJ) employees framing the DOJ's current policies and enforcement priorities. These shifting enforcement priorities are aligned...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

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

The Volkov Law Group

Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm

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DOJ has promised an aggressive criminal corporate enforcement program against sanctions violators. The storm is coming and will arrive soon with a bang. There is no question that DOJ's enforcement initiative is coming -- it...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

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

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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

Foley Hoag LLP

CEP Revisions Incentivize “Extraordinary” Corporate Cooperation

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Earlier in January 2023, the U.S. Department of Justice (DOJ) announced revisions to its Corporate Enforcement Policy (CEP) under the Foreign Corrupt Practices Act (FCPA) for the first time since 2017. In his speech...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for September 2022

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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 case developments from the past month,...more

The Volkov Law Group

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

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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)

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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

Hogan Lovells

DOJ announces white collar initiatives to pursue individuals and assist victims

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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

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

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