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Department of Justice (DOJ) Bribery Cartels

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

Nossaman LLP

DOJ Issues New FCPA Enforcement Guidelines

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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

Baker Donelson

Update: DOJ Issues Guidelines for Protectionist FCPA Enforcement

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In February, the White House issued an Executive Order "pausing" Foreign Corrupt Practices Act (FCPA) enforcement for 180 days, to "further American economic and national security."1 On June 9, Deputy Attorney General Todd...more

Dorsey & Whitney LLP

New DOJ Guidelines Mark the End of the FCPA Enforcement “Pause”

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On June 9, 2025, Department of Justice (“DOJ”) Deputy Attorney General Todd Blanche issued the highly anticipated “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (the “Guidelines”),...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)

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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

K&L Gates LLP

The FCPA is Back—What Companies Need to Know About DOJ's New America-First Enforcement Priorities

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On 9 June 2025, Deputy Attorney General Todd Blanche released a memo (the Blanche Memo) detailing the long-awaited enforcement guidelines on how the Department of Justice (DOJ) under Attorney General Pam Bondi will enforce...more

Venable LLP

FCPA Enforcement Resumes with New Guidelines Focused on Strategic U.S. Interests

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The pause on enforcement of the Foreign Corrupt Practices Act (FCPA) is over. On June 9, the Deputy Attorney General of the Department of Justice (DOJ) issued a memorandum (the June 9 Memorandum) establishing new enforcement...more

Benesch

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

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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

Husch Blackwell LLP

DOJ Poised to Reboot FCPA Investigations and Enforcement

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Issued on February 10, 2025, Executive Order 14209 (“Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security”) called on the Department of Justice (DOJ) to “review guidelines and...more

Paul Hastings LLP

New DOJ FCPA Guidelines Target Cases Linked to US Strategic Interests

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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

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

WilmerHale

Department of Justice Announces FCPA Guidelines

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On June 10, 2025, the Deputy Attorney General issued the highly anticipated Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) (“Guidelines”), complying with the directive in President...more

J.S. Held

South of the Border Compliance: Enhancing Integrity & Risk Management in Latin American Operations

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In February 2025, the Trump administration directed a significant shift in the US Department of Justice’s (DOJ) enforcement priorities by announcing a 180-day suspension of new actions under the Foreign Corrupt Practices Act...more

Morgan Lewis

Cartels, TCOs, ‘Instrumentalities of a Government’: Reassessing FCPA Risk Amid Shifting US Enforcement Priorities

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Whether cartels do or do not qualify as “instrumentalities of a government” under current FCPA law or based on the AG’s forthcoming revised FCPA guidance, their entanglement with corrupt officials and influence over local...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

BakerHostetler

Why Your Company Still Needs to Care About the FCPA (& FEPA)

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This shift in FCPA enforcement priorities is the latest move by the administration in its all-out war against cartels and TCOs that pose a threat to U.S. national security and its stated America First agenda. Additionally,...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

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

Wiley Rein LLP

AG Bondi Refocuses DOJ Priorities in New Guidance Documents

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On February 5, newly confirmed Attorney General Pam Bondi issued a series of guidance documents refocusing U.S. Department of Justice (DOJ) priorities for the new Administration. In addition to effectuating many of President...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for February 2023

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

J&F Investmentos Subsidiary, Pilgrim’s Pride, Agrees to $110 its Million Penalty for Antitrust Cartel in Chicken Processing...

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Shortly before announcing its comprehensive FCPA settlement with DOJ and the SEC, Pilgrim’s Pride agreed with the Justice Department’s Antitrust Division to plead guilty to price-fixing in the chicken processing industry....more

The Volkov Law Group

Parallel Universes: Antitrust Leniency and the FCPA Pilot Program

The Volkov Law Group on

The world of science fiction can be exhilarating. If you ever read The Foundation Trilogy or Martian Chronicles, you know what I mean. The concept of parallel universes has always been an intriguing idea where believers can...more

The Volkov Law Group

The Antitrust Leniency Model and FCPA Enforcement

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I am always wary of simplistic policy proposals – often the simple idea to apply one policy to another subject matter, just does not work. Instead, policy debate will turn to the simple idea and how it can easily be applied...more

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