On February 10, President Donald J. Trump signed an executive order and accompanying fact sheet directing U.S. Attorney General (AG) Pam Bondi to pause the initiation of new investigations and enforcement actions, and to...more
Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more
The Justice Department and the Securities Exchange Commission are back in business. The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021. While many commentators sought to read the...more
Late Monday, the Department of Justice (DOJ) without fanfare, released an update to its 2019 Evaluation of Corporate Compliance Programs, the 2019 Guidance. ...more
The Justice Department and the SEC are tired of investigating companies with “paper” compliance programs. It is easy to spot a “paper” compliance program – as the saying goes, you can smell it a mile away....more