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Criminal Prosecution Department of Justice (DOJ) Cartels

McCarter & English, LLP

2025 Criminal Antitrust Roundup

The Department of Justice Antitrust Division (DOJ) has had a busy first half of the year announcing a first-of-its-kind antitrust whistleblower program, new indictments, and several sentencing and fine decisions. Below is a...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for June 2025

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 enforcement developments from the past...more

The Volkov Law Group

Episode 377 -- Refocusing Due Diligence on Cartels and TCOs

The Volkov Law Group on

Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge - the urgent need to unravel their supply chains and the immediate...more

The Volkov Law Group

Refocusing Due Diligence on Cartel and TCOs (Part I of II)

The Volkov Law Group on

Companies face a dual challenge — the pressing need to unravel their supply chains, and the immediate task of recalibrating due diligence systems to examine potential presence of cartel and transnational criminal...more

Latham & Watkins LLP

DOJ Focuses FCPA Enforcement With New Guidelines

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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

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

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

BakerHostetler

FCPA Enforcement Is Back with a New Enhanced Focus on Protecting US Business Abroad, National Security, Individuals and (of...

BakerHostetler on

U.S. Department of Justice (DOJ) Deputy Attorney General Todd Blanche issued a memorandum on June 9 (the Memo), announcing DOJ will resume enforcement of the Foreign Corrupt Practices Act (FCPA) after its brief hiatus....more

Paul Hastings LLP

New DOJ FCPA Guidelines Target Cases Linked to US Strategic Interests

Paul Hastings LLP on

On June 9, U.S. Deputy Attorney General Todd Blanche issued a memorandum entitled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA),” which establishes guidelines to ensure that FCPA...more

White & Case LLP

DOJ Already Filing Material Support Charges After Designating Cartels as Foreign Terrorist Organizations

White & Case LLP on

On February 20, 2025, the United States designated eight cartels and transnational criminal organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). Since then, the US...more

DLA Piper

Three State-Level Developments Could Change the US Criminal Antitrust Enforcement Landscape

DLA Piper on

State attorneys general (AGs) have recently signaled a more aggressive stance toward their own criminal antitrust enforcement. If they realize their ambitions, this could presage a notable shift in the US enforcement...more

Morrison & Foerster LLP

Quarterly Cartel Catch-Up – The Trump Administration’s Criminal Antitrust Enforcement Posture Takes Shape

As previously predicted, the new year and change of administration in the U.S. brought a series of notable developments in criminal antitrust enforcement. Recent actions indicate that the new antitrust leadership in the...more

WilmerHale

Implications of EO 14157 and Recent “Foreign Terrorist Organization” and “Specially Designated Global Terrorist” Designations

WilmerHale on

On January 20, 2025, President Donald J. Trump signed Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists” (EO 14157)....more

Bracewell LLP

Trump Administration Efforts to Eliminate Cartels Pose Heightened Risk for Financial Institutions

Bracewell LLP on

As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Understanding and Mitigating Legal and Compliance Risks Relating to Cartels and Transnational Criminal Organizations

On his first day in office, President Trump signed Executive Order 14157 calling for the designation of certain cartels and transnational criminal organizations (TCOs) as foreign terrorist organizations (FTOs) or specially...more

King & Spalding

State Criminal and Civil Liability for Material Support: How the FTO Designation of Drug Cartels Increases the Risk of State...

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The State Department’s February 20, 2025, designation of specific Mexican drug cartels and Transnational Criminal Organizations (TCOs) as foreign terrorist organizations (FTOs) creates serious new risks for businesses...more

Axinn, Veltrop & Harkrider LLP

Conspiracy Theories Newsletter, 2025 Edition: Predictions for Cartel Enforcement Under Trump 2.0

In many ways, criminal antitrust enforcement during President Trump’s first term illustrates what to expect under Trump 2.0. Among other highlights, the Delrahim DOJ obtained indictments and pleas involving public procurement...more

Hogan Lovells

Spring into 2025: Key Trends in Global Cartel Enforcement

Hogan Lovells on

Despite geopolitical uncertainty and regime changes, global cartel enforcement has remained relatively steady over the last few years. That is not to say, however, that cartel investigations and private cartel enforcement...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

Seward & Kissel LLP

Pausing Bribery Prosecutions: What Companies Need to Know

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Last week President Trump signed an Executive Order pausing enforcement of the nation’s most robust anti-bribery statute, the Foreign Corrupt Practices Act (“FCPA”). The EO seeks a complete overhaul of the FCPA enforcement...more

Cozen O'Connor

U.S. Dials Back Implementation of Foreign Corrupt Practices Act

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On February 10, 2025, President Trump signed an executive order instructing the Department of Justice (DOJ) and Attorney General (AG) Pamela Bondi to “cease initiation of any new [Foreign Corrupt Practices Act (FCPA) (15...more

Holland & Knight LLP

A Game-Changer Relating to FCPA Enforcement

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U.S. Attorney General (AG) Pam Bondi on her first day in office – Feb. 5, 2025 – sent several memos to all employees of the U.S. Department of Justice (DOJ) laying out top priorities. In one memo, the DOJ instructs its...more

Snell & Wilmer

New Memoranda Issued by Attorney General Bondi: Department of Justice Corporate Enforcement Topics

Snell & Wilmer on

Pam Bondi was sworn into office as the United States Attorney General on February 5, 2025, and immediately issued a bevy of memoranda advancing the Trump Administration’s priorities. The memorandum entitled General Policy...more

Womble Bond Dickinson

DOJ Narrows FCPA Enforcement Focus

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Attorney General (AG) Pam Bondi has issued a directive that both: (1) effectively shifts the DOJ’s FCPA enforcement focus towards those cases related to foreign bribery involving cartels and transnational criminal...more

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