News & Analysis as of

Criminal Prosecution Foreign Corrupt Practices Act (FCPA) Corporate Misconduct

McCarter & English, LLP

DOJ Criminal Division Announces White Collar Enforcement Priorities and Policy Changes to White Collar Investigations

Earlier this week, the US Department of Justice (DOJ) released a new white collar enforcement plan (Enforcement Plan) outlining changes to the Criminal Division’s white collar enforcement priorities to align more closely with...more

BakerHostetler

The DOJ Announces Administration’s Revised Corporate Enforcement Strategy

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On May 12, 2025, Matthew Galeotti, Head of the Department of Justice’s (DOJ) Criminal Division, unveiled a comprehensive white collar enforcement strategy titled “Focus, Fairness, and Efficiency in the Fight Against...more

Hogan Lovells

DOJ corporate enforcement overhaul: More declinations, fewer monitors, and FCPA enforcement still in question

Hogan Lovells on

On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to key corporate criminal enforcement policies. The revisions’ stated aim is to provide more clarity and certainty of outcome to companies that...more

Womble Bond Dickinson

DOJ Announces Key Corporate Enforcement Changes & White-Collar Priorities

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DOJ recently announced white-collar crime enforcement priorities and significant changes to its corporate enforcement policies (here and here). “[O]verbroad and unchecked corporate and white-collar enforcement burdens U.S....more

White & Case LLP

Ten Takeaways from the DOJ Criminal Division’s New Playbook on White Collar Enforcement Priorities

White & Case LLP on

On May 12, 2025, the U.S. Department of Justice ("the DOJ" or "the Department") unveiled its new playbook for prosecuting white-collar and corporate crime. DOJ announced enforcement priorities for the Criminal Division ("the...more

Gray Reed

Bad Guys in Energy Paid the Piper in 2024

Gray Reed on

As in every year, in 2024 the grinches of law enforcement brought financial and corporal misery to bad guys in energy. Here is a review of the crimes of only a few of the convicted, admitted and alleged bribsters, swindlers...more

A&O Shearman

US Attorney For The District of New Jersey Reverses Course And Requests Adjournment For Foreign Bribery Case Against Tech...

A&O Shearman on

On March 4, 2025, one day before a trial against former tech executives for alleged foreign bribery charges was set to commence, the United States Attorney for the District of New Jersey requested 180-day adjournment. The...more

K&L Gates LLP

President Trump Orders FCPA Freeze; DOJ Announces Major Policy Realignment De-Emphasizing Corporate Investigations and Enforcement

K&L Gates LLP on

The much-heralded end to prosecutions brought pursuant to the Foreign Corrupt Practices Act (FCPA) never materialized during the first Donald Trump administration, but Trump 2.0 has the potential to bring major change to the...more

Ballard Spahr LLP

Attorney General Bondi Overhauls Justice Priorities

Ballard Spahr LLP on

The new administration has signaled that the Department of Justice (“DOJ”) will significantly shift its approach to criminal corporate enforcement. Specifically, on February 5, 2025, newly-confirmed United States Attorney...more

Lowenstein Sandler LLP

Long Live the FCPA?

Lowenstein Sandler LLP on

The Trump administration has taken significant action this week to overhaul the executive branch’s long-standing policy toward the prosecution of white collar offenses. First, a memo issued by newly confirmed U.S. Attorney...more

Akin Gump Strauss Hauer & Feld LLP

Analyzing the Attorney General’s FCPA Enforcement Shift

UPDATE: President Signs Executive Order Directing DOJ to Pause All FCPA Enforcement for 180 Days - On February 10, 2025, President Trump issued an Executive Order directing the U.S. Department of Justice (DOJ) to pause all...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

The Volkov Law Group

FCPA Predictions: Don’t Expect Much to Change

The Volkov Law Group on

In 2017, when President Trump first took office, big changes were expected in FCPA enforcement.  Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA.  He was not a big fan of the law and...more

The Volkov Law Group

DOJ’s Balancing Act — Incentives to Cooperate and Deterrence (Part III of III)

The Volkov Law Group on

While DOJ did not have an overwhelming FCPA enforcement year, DOJ has devoted significant energy to tweaking its enforcement and compliance policies.  These measures were believed to coincide with a number of significant...more

The Volkov Law Group

The FCPA Year in Review — More of the Same with Some Twists (Part I of III)

The Volkov Law Group on

With the end of the Biden Administration, it is hard to identify a consistent theme relating to FCPA enforcement.  On the one hand, the Biden Administration talked a big game, elevating the anti-corruption fight as a national...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

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2024

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

Nelson Mullins Riley & Scarborough LLP

Bringing Moths to the Flame: DOJ Promises Non-Prosecution to Execs for Tips to Combat Corporate Crime

Recently, the Department of Justice (DOJ) Criminal Division launched a pilot program promising “mandatory NPAs to incentivize individuals (and their counsel) to provide original and actionable information.” This most recent...more

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action-Part 3-The Penalty

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary...more

Benesch

White Collar Quarterly Report | Q1 2024

Benesch on

We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more

Thomas Fox - Compliance Evangelist

Argentieri at ABA White Collar Conference: Corporate Enforcement, Part 1

There were recently two significant speeches by Department of Justice (DOJ) officials at the American Bar Association National Institute on White Collar Crime. The first was by Deputy Attorney General Lisa Monaco. The second...more

The Volkov Law Group

Gunvor Falls Under FCPA Axe and Agrees to Pay Criminal Penalty of $661 Million (Part I of III)

The Volkov Law Group on

You have to give the Justice Department credit — after two slow enforcement years, DOJ is starting off 2024 with a relative “bang;” first, DOJ reached a large settlement with SAP in January, and now, DOJ has reached a...more

The Volkov Law Group

Former Stericyle Official Charged in Foreign Bribery Scheme

The Volkov Law Group on

According to the terms of a superseding information made public by the U.S. Attorney’s Office for the Southern District of New York on or about February 13, 2024, Mauricio Gomez Baez (“Baez”)—a former Stericycle executive for...more

BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

BakerHostetler on

At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Compelled Interviews Admissible in Criminal Prosecution Against Former Company President and Its General Counsel

A New Jersey federal court has ruled that a company’s self-disclosure of potential Foreign Corrupt Practices Act (FCPA) violations did not render the company a state actor, allowing evidence obtained by its internal...more

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