News & Analysis as of

Corruption Enforcement Actions Investigations

American Conference Institute (ACI)

Unpacking the Department of Justice’s New FCPA Enforcement Priorities

New guidelines governing Foreign Corrupt Practices Act (FCPA) investigations and enforcement effectively signal the official end of the proclaimed FCPA enforcement pause announced by President Trump earlier in the year, while...more

Wiley Rein LLP

DOJ’s Approach to White Collar Enforcement: Target Those Who Harm U.S. Interests While Minimizing Collateral Damage

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The U.S. Department of Justice (DOJ) recently announced Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA). The June 9 memorandum from Deputy Attorney General Todd Blanche instructs...more

The Volkov Law Group

DOJ’s Fresh FCPA Enforcement Initiative — What’s New, What’s Not (Part II of II)

The Volkov Law Group on

DOJ’s new approach to FCPA enforcement presents some interesting opportunities — the headlines from the DOJ FCPA Guidance Memo will bring some significant changes but at the same time some things will not change.  Here is my...more

Cadwalader, Wickersham & Taft LLP

The Pause is Over—the FCPA Lives On

On June 9, 2025, the U.S. Department of Justice (DOJ) announced the resumption of Foreign Corrupt Practices Act (FCPA) enforcement, ending the enforcement pause initiated by Executive Order 14209. In doing so, Deputy Attorney...more

Skadden, Arps, Slate, Meagher & Flom LLP

Deputy Attorney General Issues FCPA Guidelines Resuming Limited Enforcement

Key Points - - The U.S. Department of Justice (DOJ) will resume investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA), prioritizing, in part, FCPA actions involving cartels and transnational...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

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments: 2024 Year in Review

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this special edition of our award-winning monthly Top 10 International Anti-Corruption Developments newsletter summarizes the most...more

DLA Piper

Cartel Enforcement is Evolving Across the Americas. Here Are Three Aspects to Consider

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Competition enforcers throughout the Americas focus their efforts to investigate and prosecute antitrust cartels: agreements between competitors to fix prices, rig bids, or allocate markets....more

Bracewell LLP

Digging for Trouble: The Double-Edged Sword of Decisions to Report Misconduct

Bracewell LLP on

On May 10, 2024, Romy Andrianarisoa, former Chief of Staff to the President of Madagascar, was convicted for soliciting bribes from Gemfields Group Ltd (Gemfields), a UK-based mining company specializing in rubies and...more

Jones Day

Raids by Asia-Pacific Enforcers Are on the Rise: A Guide to Being Prepared for When the Enforcer Comes Knocking

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The Development: After an interruption during the COVID-19 pandemic, authorities across the Asia-Pacific region have fully revived dawn raids....more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 10, Getting to Self-Disclosure: Speak Up, Triage and Internal...

Over this series, I have reviewed the messages communicated by the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) from three key Foreign Corrupt Practices Act (FCPA) enforcement actions regarding...more

A&O Shearman

Top ten challenges for white collar crime and investigations lawyers in 2023

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We asked our global white collar crime team for their views on key challenges in 2023 for in‑house investigations teams and white collar crime lawyers, and how to manage the associated risks. Here are their top ten....more

Hogan Lovells

World Bank investigations spike and highlight integrity risks in private sector development finance

Hogan Lovells on

Ignoring integrity risks in emerging markets when receiving financing from the World Bank Group (WBG) is about to become much riskier, as the WBG Sanctions System Annual Report for Fiscal Year 2022 (FY22) indicates. The...more

Steptoe & Johnson PLLC

Department of Justice Ramps Up Scrutiny of Businesses In White-Collar Cases, Will Consider Using “Monitors”

Steptoe & Johnson PLLC on

Deputy U.S. Attorney General Lisa Monaco, in a speech on October 28, 2021 at the American Bar Association’s White-collar National Institute Summit in Miami, announced three new initiatives relating to the prosecution of...more

K2 Integrity

Digging Deeper Episode 8: Investigating Corruption in Argentina

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Lazaro Baez was recently sentenced to 12 years in jail for money laundering in Argentina, charges that connected him to political powers still at large in the country....more

Sheppard Mullin Richter & Hampton LLP

The Next Four Years of FCPA Enforcement: What to Expect From the Biden Administration

Contrary to some expectations, the Trump Administration Department of Justice imposed record penalties under the U.S. Foreign Corrupt Practices Act from 2017 through 2020. But in each of those years, fewer and fewer new FCPA...more

The Volkov Law Group

Swiss Telecomm Company Pays $7.8 Million to Settle OFAC Sanctions Violations

The Volkov Law Group on

OFAC continues to aggressively enforce its sanctions programs.  In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an...more

Herbert Smith Freehills Kramer

Danske Bank Under Investigation in France

Danske Bank is likely to again become the target of a formal investigation in France. A Paris court began investigating Danske Bank in October 2017 in relation to transactions of its Estonian branch, between 2008 and 2011,...more

Foodman CPAs & Advisors

Winning Business Through Bribery Could Get You Into Trouble!

Foodman CPAs & Advisors on

The FCPA prohibits an offer, payment, promise or the authorization of a payment of money or anything of value (a/k/a bribery) to a foreign official for the purpose of obtaining or retaining business....more

Thomas Fox - Compliance Evangelist

Evolution of Best Practices – Part IV

In addition to enforcement actions, the Department of Justice’s (DOJs) 2016 FCPA Pilot Program, coupled with 2017’s Evaluation of Corporate Compliance Programs (Evaluation) and the FCPA Corporate Enforcement Policy, all...more

King & Spalding

SEC Cracks Down on Charitable Contributions under the FCPA - Best Practices In Light of Recent SEC Enforcement

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For the first time, the Securities and Exchange Commission has brought an FCPA enforcement action premised entirely on a one-time charitable contribution. On September 20, 2016, the SEC announced a settled FCPA...more

Morgan Lewis

Lessons Learned from Nu Skin

Morgan Lewis on

The enforcement action against manufacturer Nu Skin Enterprises highlights the risks of making charitable donations in high-risk countries without conducting meaningful anticorruption due diligence....more

The Volkov Law Group

Three Key Takeaways from the Nu Skin FCPA Settlement for a Corrupt Charitable Donation

The Volkov Law Group on

In a rare enforcement action, the SEC settled an FCPA enforcement action for $766,000 for a charitable donation of $154,000 to improperly influence a high-ranking Chiese Communist party official to prevent a provincial agency...more

The Volkov Law Group

FCPA Enforcement Actions and Reputational Damage

The Volkov Law Group on

If you ask members of a corporate board or senior executives about the cost of an FCPA enforcement action, they will candidly acknowledge all of the costs – fines, penalties, and professional costs (e.g. legal, accounting,...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions

In this episode, I review the corporate FCPA enforcement actions of 2013. ...more

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