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Department of Justice (DOJ) Corporate Misconduct National Security

Husch Blackwell LLP

DOJ Declines to Prosecute Private Equity Firm After Self-Disclosure Related to Acquired Company

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Last year, the Department of Justice (DOJ) National Security Division (NSD) updated its Enforcement Policy for Business Organizations to include guidance related to voluntary self-disclosures in connection with acquisitions....more

Morrison & Foerster LLP

DOJ Issues First-Ever Declination Under Corporate Disclosure M&A Policy

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced that it declined to charge private equity firm White Deer Management LLC (“White Deer”) and its affiliates after the company...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

Herbert Smith Freehills Kramer

DOJ resumes FCPA enforcement with new guidelines

On June 10, 2025, the head of the Criminal Division of the Department of Justice (DOJ), Matthew Galeotti, declared in a speech that the DOJ would resume enforcing the Foreign Corrupt Practices Act (FCPA). This announcement...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

BakerHostetler

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

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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

Ballard Spahr LLP

Focused FCPA Enforcement: Emphasizing Security and Strategic Interests

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On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the DAG memorandum) updating the Department of Justice’s (DOJ) enforcement guidelines for the Foreign Corrupt Practices Act (FCPA) in accordance with...more

Ropes & Gray LLP

DOJ’s New FCPA Playbook: “Time To Get To Work”

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On June 9, 2025, the U.S. Department of Justice (“DOJ” or the “Department”) issued the highly anticipated guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (“FCPA”) (“FCPA Guidelines”),...more

Robinson & Cole LLP

Legal Update: DOJ Announces Long-Awaited Corporate Enforcement Priorities

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On May 12, 2025, the Department of Justice’s (DOJ) Criminal Division issued a much-anticipated memorandum outlining its enforcement priorities and policies for prosecuting corporate and white-collar crimes. The memorandum,...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

Seward & Kissel LLP

DOJ’s White Collar Enforcement Priorities: What’s In, What’s Out

Seward & Kissel LLP on

On May 12, the Criminal Division of the U.S. Department of Justice (DOJ) issued a series of changes in its white collar enforcement priorities. These changes were announced in the Criminal Division Enforcement Plan, the...more

Baker Donelson

Shifting Priorities: DOJ's New Approach to White Collar Enforcement

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The U.S. Department of Justice (DOJ) announced on May 12, 2025, a strategy shift in its approach to white collar enforcement, identifying specific high-impact areas of focus; an expansion of whistleblower and self-disclosure...more

BakerHostetler

The DOJ Announces Administration’s Revised Corporate Enforcement Strategy

BakerHostetler on

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

Faegre Drinker Biddle & Reath LLP

DOJ National Security Division Issues Second Declination Since Issuance of Revised Corporate Enforcement Policy

On April 30, 2025, the National Security Division (NSD) of the Department of Justice (DOJ) announced the declination of prosecution against the Universities Space Research Association (USRA), a federal government contractor,...more

The Volkov Law Group

Quadrant Magnetics Executives Plead Guilty to ITAR Violations for Transmitting Controlled Technical Data to China

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Heightened federal scrutiny of unauthorized technology transfers to foreign entities has once again resulted in high-profile criminal convictions, as two senior executives of Quadrant Magnetics, a Kentucky-based manufacturer...more

Lathrop GPM

Trump Executive Order Pausing FCPA Enforcement: Have Legal Requirements Changed?

Lathrop GPM on

One of the most notable developments in the anti-corruption world is the Trump Administration’s Feb. 10 Executive Order, “Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security.” ...more

Carlton Fields

President Trump Issues Executive Order Pausing Enforcement of FCPA: A Sea Change Moment for DOJ and SEC

Carlton Fields on

On February 10, 2025, President Trump issued Executive Order 14209, titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security,” with the stated purpose of eliminating...more

K&L Gates LLP

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

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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

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

Guidepost Solutions LLC

Monitoring Against Whistleblower Retaliation

Guidepost Solutions LLC on

Saves Lives, Prevents Major Crimes, and Accelerates Voluntary Self - Disclosures The U.S. Department of Justice (“DoJ”) recently spotlighted its Whistleblower Awards Program and Voluntary Self Disclosure (“VSDs”)...more

Robinson & Cole LLP

Legal Update: Department of Justice National Security Division Announces First-of-Its-Kind Declination under Its Voluntary...

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On May 22, 2024, the Department of Justice (DOJ) announced the first-ever declination under the National Security Division’s recently updated Enforcement Policy for Business Organizations (NSD Policy). The NSD Policy offers...more

Wilson Sonsini Goodrich & Rosati

National Security Division’s Voluntary Self-Disclosure Policy in Action: Exchanging Cooperation for Declination

Last month, the U.S. Department of Justice (DOJ) announced that it would not charge MilliporeSigma, a life sciences company, even though one of its employees falsified export documents. The DOJ declined to prosecute...more

Paul Hastings LLP

NDCA’s New Whistleblower Pilot Program: A Unique Focus on Reporting Intellectual Property Theft

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On March 18, 2024, Ismail Ramsey (“Ramsey”), the U.S. Attorney for the Northern District of California (“NDCA”), announced the launch of NDCA Whistleblower Pilot Program (the “Pilot Program”), a significant new policy that...more

Akin Gump Strauss Hauer & Feld LLP

DOJ National Security Division Updates Corporate Crime Enforcement Policy and Issues Whistleblower Policy

Executive Summary - - On March 7, 2024, the NSD of the DOJ issued an updated NSD Enforcement Policy to include a new section covering VSDs in connection with mergers and acquisitions. - These updates follow repeated...more

Goodwin

In Continuing Efforts to Incentivize Self-Disclosures and Cooperation, DOJ Announces Pilot Program to Pay Criminal Whistleblowers

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Over the last few years, the U.S. Department of Justice (“DOJ”) has continuously announced significant policies and programs directed at encouraging and rewarding the timely reporting of corporate wrongdoing, incentivizing...more

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