News & Analysis as of

Department of Justice (DOJ) Cross-Border Transactions Enforcement Actions

Orrick, Herrington & Sutcliffe LLP

5 Things In-House Counsel Must Know Before DOJ’s Bulk Transfer Rule Enforcement Begins

The Department of Justice’s (DOJ) 90-day grace period for compliance with the Data Security Program (DSP) ends on July 8, 2025, and enforcement is expected to begin. This regulatory regime was created for national security...more

Baker Donelson

Digital Marketing Meets DOJ Oversight: What Businesses with Digital Campaigns Should Do to Manage AdTech Risks

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With the ease of apps and websites for planning activities, whether it be vacations, business trips, or shopping, we open ourselves to multiple sources of being followed across devices by collecting, analyzing, and sharing...more

Porter Hedges LLP

DOJ Issues New Guidelines Narrowing FCPA Enforcement Scope

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On June 9, 2025, the Department of Justice (DOJ) released updated guidelines governing the enforcement of the Foreign Corrupt Practices Act (FCPA), signaling a more focused and strategic approach to foreign bribery cases. The...more

White & Case LLP

The Shadow Financial System

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The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

Jenner & Block

Client Alert: White House Executive Order Seeks to Protect Americans’ Sensitive Personal Data and US Government-Related Data in...

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On February 28, 2024, President Biden issued Executive Order 14117 on Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern (the EO). The EO empowers...more

Oberheiden P.C.

Internal Audit for FCPA Compliance: A Detailed Guide

Oberheiden P.C. on

The Foreign Corrupt Practices Act (FCPA) (15 U.S.C. § 78dd-1 et seq.) is a federal anti-bribery law that makes it unlawful for certain people to pay foreign government officials in order to conduct business abroad. While it...more

American Conference Institute (ACI)

Compliance measures to address sanctions enforcement: ‘the new FCPA’

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

Goodwin

2021 Year in Review: FCPA

Goodwin on

A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

McDermott Will & Emery

International Legal Highlights - May 2021

McDermott Will & Emery on

Expect More Criminal Enforcement & What You Can Do To Minimize Your Risk - Antitrust cartel and related collusive scheme enforcement is poised to increase. Several factors support this: (1) the Antitrust Division (the...more

Faegre Drinker Biddle & Reath LLP

The U.S. Department of Justice Releases its Cryptocurrency Enforcement Framework

Earlier this year, the U.S. Department of Justice (“DOJ”) released its highly anticipated Cryptocurrency Enforcement Framework (the “Framework”).  The Framework was developed as part of the Attorney General’s Cyber-Digital...more

White & Case LLP

DOJ Global Corruption Efforts Beyond the FCPA

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Although courts have reined in the application of the Foreign Corrupt Practices Act (FCPA) anti-bribery provisions in the past two years, the US Department of Justice (DOJ) shows no sign of scaling back its global...more

Perkins Coie

Rare DOJ Opinion Offers Anti-Bribery Lessons for Transactions Involving Foreign Government-Owned Assets

Perkins Coie on

The U.S. Department of Justice (DOJ) has issued an opinion letter (catalogued as FCPA Opinion No. 20-01) stating that it does not intend to take enforcement action under the Foreign Corrupt Practices Act (FCPA) against a...more

Skadden, Arps, Slate, Meagher & Flom LLP

Takeaways From the ABA/IBA International Cartel Workshop

In February, the American Bar Association’s Section of Antitrust Law and the International Bar Association’s Antitrust Committee hosted the 13th International Cartel Workshop in San Francisco. Over the course of three days,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Katten Muchin Rosenman LLP

Bridging the Week - November 2019 #2

A social media company and its wholly owned subsidiary sued by the Securities and Exchange Commission for conducting an offering of an unregistered digital security claimed that the agency was wrong in its characterization of...more

Thomas Fox - Compliance Evangelist

Congrats to the Nats and the Jho Low Forfeiture Agreement

As reported by Byron Tau and Aruna Viswanatha in the Wall Street Journal (WSJ), “Jho Low, the businessman-turned-fugitive accused of masterminding a multibillion-dollar fraud involving Malaysia’s sovereign-wealth fund, agreed...more

Ballard Spahr LLP

DOJ Charges Turkish State-Owned Halkbank With Money Laundering, Fraud, and Iran-Related Sanctions Offenses

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Indictment Alleges that Bank and its Officers Used Front Companies to Evade Prohibitions on Iran’s Access to the U.S. Financial System - The U.S. Attorney for the Southern District of New York has charged Turkish state-owned...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - September 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more

Ballard Spahr LLP

The EU’s Efforts to Combat Money Laundering, the Financing of Terrorism and Corruption Seem to Overlook a Very American Approach:...

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The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including the use of legal holds in cross-border investigations,...more

Snell & Wilmer

Global Connection - January 2018

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Dear Friend of Snell & Wilmer: The past year brought significant changes across a variety of political, legal, and policy spheres, and the world of U.S. international trade law was no exception. This edition of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Sapin II Act: New Perspectives on Cross-Border Investigations

On November 30, 2017, the Institut des Hautes Etudes sur la Justice (IHEJ) and Skadden hosted a roundtable at the Cercle de l’Union Interalliée in Paris to discuss new perspectives on the Sapin II Act and cross-border...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - November 2017

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including new U.K. reporting obligations for sanctions violations,...more

Skadden, Arps, Slate, Meagher & Flom LLP

China’s ‘One Belt, One Road’ Initiative Creates Opportunities and Regulatory Challenges

In a time of shifting opinions on the benefits of globalization, China’s “One Belt, One Road” initiative (OBOR) offers an unexpected bright spot for multinational companies able and willing to participate in this...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross Border Investigations Update - July 2017

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases and enforcement trends, including the new Criminal Finances Act 2017, increased regulatory scrutiny of Chinese companies...more

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