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Criminal Investigations Bribery

Morgan Lewis

DOJ FCPA Declination Points to Continuation of Policies and Importance of Robust Compliance

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An August 7, 2025 declination agreement published by the US Department of Justice’s (DOJ’s) Fraud Section—and the first bribery DOJ resolution of President Trump’s second term—provides initial insights into declinations under...more

Nossaman LLP

DOJ Issues New FCPA Enforcement Guidelines

Nossaman LLP on

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

Latham & Watkins LLP

DOJ Focuses FCPA Enforcement With New Guidelines

Latham & Watkins LLP on

DOJ issues updated guidelines, ending temporary “pause” on FCPA enforcement and focusing potential enforcement on priority areas. On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the Guidelines)...more

Bradley Arant Boult Cummings LLP

DOJ Issues FCPA Investigations and Enforcement Guidelines

On February 10, 2025, President Donald J. Trump signed Executive Order 14209, titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.” That order marked a major shift in...more

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

Cozen O'Connor

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

Cozen O'Connor on

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

DarrowEverett LLP

The DOJ’s New White-Collar Agenda: Implications for Businesses

DarrowEverett LLP on

On May 12, 2025, the Department of Justice (the “DOJ”) released its criminal—and, more specifically, white collar crime enforcement—initiatives under the current administration. This is typical each time new leadership...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

Latham & Watkins LLP on

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

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

The Volkov Law Group

McKinsey Company Pays $122 Million to Resolve FCPA Violations in South Africa (Part I of III)

The Volkov Law Group on

On December 5, 2024, DOJ announced a settlement with McKinsey and Company for $122 million for bribes paid to South African government officials to secure valuable consulting contracts....more

Alston & Bird

The Wait Is (Almost) Over: The UK’s “Failure to Prevent Fraud” Guidance Is Here, and the Offense Itself Is Not Far Behind

Alston & Bird on

Our White Collar, Government & Internal Investigations Team discusses the UK’s new guidance on the “failure to prevent fraud” offense. The guidance addresses the “failure to prevent fraud” offense created by the Economic...more

The Volkov Law Group

Raytheon’s False Claims Act Settlement (Part IV of IV)

The Volkov Law Group on

The Justice Department’s global settlement included a significant False Claims Act resolution, resulting in a second deferred prosecution agreement (“DPA”) for a three-year term. A criminal information was filed in the...more

WilmerHale

Nick Ephgrave’s First Year as SFO Director

WilmerHale on

Nick Ephgrave QPM, the Director of the Serious Fraud Office (“SFO”), recently marked the end of his first year in office. Ephgrave has brought a renewed energy, sense of purpose and proactive approach to the SFO, opening six...more

Wiley Rein LLP

Wicked Coin: The "Fat Leonard" Scandal

Wiley Rein LLP on

Power and corruption … two sides of a Wicked Coin. In this podcast, hosts Tatiana Sainati, co-chair of Wiley’s Global Disputes Practice, and Diana Shaw, a partner in Wiley’s White Collar & Government Investigations Practice...more

The Volkov Law Group

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

The Volkov Law Group on

The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination.  But even a declination comes with a requirement — the company has...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

WilmerHale

UK Criminal Enforcement Update - Spring 2024

WilmerHale on

Recent weeks have seen several notable developments in the UK criminal enforcement landscape...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

Sheppard Mullin Richter & Hampton LLP

DOJ Pilot Program for Whistleblower Rewards: The Latest Unveiling from the ABA’s National Institute on White Collar Crime

While most legal conferences may not be newsworthy, the American Bar Association’s National Institute on White Collar Crime is an exception. Indeed, the federal government’s chief law enforcers seem to treat this particular...more

WilmerHale

‘One eye across the Atlantic’ - The UK SFO Director’s Maiden Speech and Recent Visits to the United States Underscore the...

WilmerHale on

The Director of the UK Serious Fraud Office (SFO), Nick Ephgrave QPM, delivered his maiden public speech on February, 13, 2024, closely followed by visits to key financial centres in the United States to meet with...more

Latham & Watkins LLP

New SFO Director Sets Tone for Tenure

Latham & Watkins LLP on

Motivated by a “visceral reaction” to large-scale economic crime, Nick Ephgrave lays out vision for a bolder, more pragmatic, and more proactive agency. Whistleblowers, dawn raids, and cross-agency collaboration are all...more

Bracewell LLP

The ENRC Saga – Not Just a UK Concern

Bracewell LLP on

On 21 December 2023, Mr Justice Waksman handed down his judgment in the second trial of the Eurasian Natural Resources Corporation (ENRC) saga. The judgment, along with its earlier companions, is extraordinary in many ways...more

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