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Department of Justice (DOJ) National Security 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

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

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

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

Womble Bond Dickinson

New FCPA Guidance By DOJ

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The Department of Justice ("DOJ") recently announced new guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (FCPA). ...more

Cozen O'Connor

DOJ Restarts Enforcement of Foreign Corrupt Practices Act, Focusing on U.S. Interests

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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

Lowenstein Sandler LLP

First Terrorism Indictments Announced Over Drug Cartel Support

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Last Friday, the U.S. Department of Justice (DOJ) unsealed its first indictment against a foreign national for providing material support to a Mexican drug cartel that the current administration recently designated a foreign...more

Bracewell LLP

Trump Administration Efforts to Eliminate Cartels Pose Heightened Risk for Financial Institutions

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As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more

Morrison & Foerster LLP

FinCEN Joins the Government-Wide Pursuit of Cartels - UPDATED 3/18/25

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more

King & Spalding

State Criminal and Civil Liability for Material Support: How the FTO Designation of Drug Cartels Increases the Risk of State...

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The State Department’s February 20, 2025, designation of specific Mexican drug cartels and Transnational Criminal Organizations (TCOs) as foreign terrorist organizations (FTOs) creates serious new risks for businesses...more

Torres Trade Law, PLLC

DOJ Memoranda Impact FCPA, FARA, and Other National Security Enforcement Priorities

President Trump’s pick for Attorney General, Pam Bondi, took quick action upon her swearing in on February 5, 2025, to make changes within the Department of Justice (“DOJ”) via the issuance of fourteen separate memorandum...more

Jones Day

Mitigating Risk From the Designation of Cartels as FTOs and SDGTs

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The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...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

Seward & Kissel LLP

Pausing Bribery Prosecutions: What Companies Need to Know

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Last week President Trump signed an Executive Order pausing enforcement of the nation’s most robust anti-bribery statute, the Foreign Corrupt Practices Act (“FCPA”). The EO seeks a complete overhaul of the FCPA enforcement...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

DLA Piper

AG Bondi Releases Memos on Cartels and Joint Task Force October 7: Implications for Industry

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The US Department of Justice (DOJ)’s Attorney General, Pam Bondi, recently released over a dozen memoranda on a variety of policies – ranging from plea agreements and sentencing criteria, to the DOJ’s amplified focus on...more

Nossaman LLP

Attorney General Walks Back FCPA to Focus on “Total Elimination of International Drug Cartels”

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The proposed expansion of the Foreign Agent Registration Act (FARA) further into private commercial activity published in the Federal Register just over a month ago may be halted due to one of the first directives issued by...more

Guidepost Solutions LLC

Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more

Holland & Knight LLP

Executive Order: Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global...

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Date Issued: Jan. 20, 2025 This executive order initiates the process of designating certain international cartels as Foreign Terrorist Organizations (FTOs) to address the rise in violence and terror across the western...more

Paul Hastings LLP

Implications for Mexican Banks and Financial Institutions of President Trump’s Designation of Drug Cartels as Foreign Terrorist...

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On his first day in office, President Donald Trump signed an executive order that initiates the process of designating certain drug cartels as foreign terrorist organizations. The executive order is primarily focused on...more

Akin Gump Strauss Hauer & Feld LLP

Designating Cartels And Other Organizations As Foreign Terrorist Organizations And Specially Designated Global Terrorists

This Order declares a national emergency under the International Emergency Economic Powers Act (IEEPA) to designate certain international cartels and other organizations as Foreign Terrorist Organizations or Specially...more

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