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Benesch

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

Benesch on

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

Fenwick & West LLP on

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

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

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

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

DLA Piper

How Argentina Reached a Turning Point for Corporate Accountability and Compliance in 2024

DLA Piper on

In 2024, Argentina experienced a pivotal moment in corporate law enforcement with the first significant application of its Corporate Criminal Liability Law No. 27,401, enacted in 2018. This law holds private entities...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

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

The Volkov Law Group

Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm

The Volkov Law Group on

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

Ballard Spahr LLP

DOJ Bolsters International Cooperation to Combat Corruption

Ballard Spahr LLP on

Summary - The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...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

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

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

Hogan Lovells

DOJ announces white collar initiatives to pursue individuals and assist victims

Hogan Lovells on

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

Morgan Lewis on

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

Goodwin

2021 Year in Review: FCPA

Goodwin on

A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

The Volkov Law Group

Joseph R. Biden, Jr. —The Anti-Corruption President?

The Volkov Law Group on

Scores of articles and volumes of commentary have been issued since President Joseph R. Biden, Jr. issued a presidential memorandum (hereinafter, “Memorandum”) making global anticorruption efforts an urgent national security...more

White & Case LLP

China Increases Penalties For Private Sector Bribery

White & Case LLP on

China’s most recent amendment to its Criminal Law updates the sentencing framework for non-state functionaries charged with corruption. Under the current framework, non-state functionaries are subject to lighter sentences...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

Jones Day on

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

White & Case LLP

DOJ Global Corruption Efforts Beyond the FCPA

White & Case LLP on

Although courts have reined in the application of the Foreign Corrupt Practices Act (FCPA) anti-bribery provisions in the past two years, the US Department of Justice (DOJ) shows no sign of scaling back its global...more

Ballard Spahr LLP

DOJ and Multi-Agency Task Force Charge International Money Laundering, Drug Trafficking, and Illegal Wildlife Trade Scheme

Ballard Spahr LLP on

“Front” Seafood Businesses Allegedly Hid the Proceeds From Smuggled Shark Fins and Marijuana Distribution - Last week, the U.S. Attorney’s Office for the Southern District of Georgia unsealed an indictment returned in July,...more

Hogan Lovells

Individual prosecutions under the FCPA – more trials and more caselaw

Hogan Lovells on

This month’s analysis looks at individual prosecutions under the Foreign Corrupt Practices Act (FCPA). Prosecutions have markedly increased over the last five years, and this will better define local, regional, and...more

Society of Corporate Compliance and Ethics...

Compliance Perspectives: Combating Corruption

When it comes to battling corruption, different countries in Latin America (and elsewhere for that matter) have different capabilities from an enforcement perspective. As Geert Aalbers, Partner at Control Risks explains in...more

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