News & Analysis as of

Criminal Prosecution Department of Justice (DOJ) Trump Administration

Davis Wright Tremaine LLP

Healthcare Industry in the Crosshairs at DOJ and HHS

Any suggestion that the Trump Administration might not be committed to healthcare fraud enforcement was definitively quashed by two recent developments. First, on July 2, 2025, the U.S. Department of Justice (DOJ) and the...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

Husch Blackwell LLP

Updated: Trump Administration Clarifies Criminal Enforcement Priorities

Husch Blackwell LLP on

On May 9, 2025, the White House issued an executive order, titled “Fighting Overcriminalization in Federal Regulations,” that could have a significant impact on the administration’s enforcement of criminal regulatory...more

Mintz - Health Care Viewpoints

Health Care Fraud Enforcement Developments: the 2025 Takedown and a “New” False Claims Act Working Group

This year’s National Health Care Fraud Takedown (Takedown) announced recently by the Department of Justice was touted by the Department of Justice (DOJ) as the largest to date, involving over $14.6 billion in “intended loss”...more

Holland & Knight LLP

CFPB Provides Guidance on Referrals for Potential Criminal Enforcement

Holland & Knight LLP on

The CFPB has issued a policy statement describing its plan to address criminally liable regulatory offenses. President Donald Trump previously issued an executive order on May 9, 2025, requiring each federal agency to publish...more

Troutman Pepper Locke

In Response to the President’s Directive, CFPB Unveils New Strategy to Tackle Criminal Regulatory Offenses

Troutman Pepper Locke on

Today, the Consumer Financial Protection Bureau (CFPB or Bureau) published a policy statement in the Federal Register outlining its approach to addressing criminally liable regulatory offenses. This publication comes in...more

Wiley Rein LLP

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

Wiley Rein LLP on

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

DLA Piper

DOJ’s Revised Policy on Crediting Fines: Emphasis on Victims

DLA Piper on

Without fanfare, the Department of Justice (DOJ or the Department) has published a memorandum revising its policy on when – and how – it will give credit to companies for fines and other payments made to other agencies,...more

McGlinchey Stafford

DOJ Overhauls Corporate Enforcement, Disclosure Policy, Offering Clearer Path to Leniency

McGlinchey Stafford on

The decision for a company to self-disclose potential criminal misconduct to the U.S. Department of Justice (DOJ) is always complex. This is particularly true during periods of administration transitions when DOJ policies and...more

Jones Day

DOJ Resumes FCPA Enforcement Under New Guidelines Prioritizing the Protection of American Interests

Jones Day on

In response to President Trump's February 10, 2025, Executive Order pausing DOJ FCPA enforcement (the "Executive Order"), on June 9, 2025, the DOJ issued new guidelines (the "Guidelines"), which prioritize the enforcement of...more

Vedder Price

DOJ Issues New FCPA Enforcement Guidelines

Vedder Price on

On June 9, 2025, the U.S. Department of Justice (DOJ) released a memorandum establishing long-awaited guidance for the investigation and enforcement of the Foreign Corrupt Practices Act (FCPA). The guidance was a direct...more

Katten Muchin Rosenman LLP

Updated FCPA Guidance

Shortly after taking office President Trump signed an executive order titled, “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.” Among other things, President Trump...more

Mayer Brown

FCPA Un-Paused: DOJ Announces New Guidelines for FCPA Enforcement

Mayer Brown on

On June 9, 2025, in a memorandum entitled Guidelines for Investigations and Enforcement of the FCPA(the “Guidelines”), the Department of Justice (DOJ) signaled that Foreign Corrupt Practices Act (FCPA) investigations and...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

Sheppard Mullin Richter & Hampton LLP

DOJ Releases Promised Guidelines for Investigation and Enforcement Under the FCPA

On Monday June 9, 2025, the Deputy Attorney General Todd Blanche released “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act.” This much anticipated update directly responds to Executive Order...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

Akin Gump Strauss Hauer & Feld LLP

DOJ Hits Play: The End of the FCPA “Pause” and Return to Enforcement

On June 9, 2025, the Deputy Attorney General issued a Memorandum detailing the administration’s new FCPA guidelines for all current and future investigations and enforcement actions. According to the Head of DOJ’s Criminal...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

Latham & Watkins LLP

Key Insights on President Trump Executive Order Limiting Criminal Enforcement of Regulatory Offenses

Latham & Watkins LLP on

The executive order shifts policy on enforcement of criminal regulatory offenses, steering away from criminal enforcement of strict liability offenses in regulatory matters....more

The Volkov Law Group

DOJ Applies False Claims Act to Tariff and Trade Violations (Part I of III)

The Volkov Law Group on

Never underestimate the creativity and ability of federal prosecutors to apply federal criminal laws to address “new” crimes or new enforcement programs. Corporate leaders and compliance officials are making a serious...more

Jones Day

DOJ Criminal Division Announces Priority Enforcement Areas and Publishes Revised Enforcement Guidance

Jones Day on

On May 12, 2025, the Department of Justice Criminal Division announced significant changes to its corporate white-collar criminal enforcement priorities. In line with the Trump administration’s recalibration toward...more

Brownstein Hyatt Farber Schreck

New Executive Order Takes Aim at the Regulatory State

On May 9, President Trump signed Executive Order (EO) 14294, “Fighting Overcriminalization in Federal Regulations.” The EO is a continuation of President Trump’s larger effort to address the “overregulation” problem that has...more

Sheppard Mullin Richter & Hampton LLP

Department of Justice Tariff Enforcement Likely to Surge After Tariff Increases and the Administration’s Increased Focus on...

A serious step up in civil and criminal enforcement of customs laws, including tariff evasion, is imminent. In a May 12 memorandum, the Department of Justice’s new Chief of the Criminal Division, Matthew Galeotti, counted as...more

Womble Bond Dickinson

The Trump Administration Takes Aim at Regulatory Overcriminalization

Womble Bond Dickinson on

On May 9, 2025, President Donald Trump issued an Executive Order entitled “Fighting Overcriminalization in Federal Regulations.” The Order takes aim at what the President calls “regulatory crimes,” with the intended purpose...more

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