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Enforcement Actions Corruption Cartels

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

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)

The Volkov Law Group on

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

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

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

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

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

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

DLA Piper

Cartel Enforcement is Evolving Across the Americas. Here Are Three Aspects to Consider

DLA Piper on

Competition enforcers throughout the Americas focus their efforts to investigate and prosecute antitrust cartels: agreements between competitors to fix prices, rig bids, or allocate markets....more

The Volkov Law Group

HR and CCOs Watch Out!! — The Antitrust Division Doubles Down on Labor Market Criminal Cartel Activity

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The Justice Department’s Antitrust Division has targeted collusion in labor markets for criminal prosecution.  This was not unexpected.  Indeed, the Antitrust Division gave plenty of warning to companies that criminal...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

DOJ Criminal Generic Pharma Price-Fixing Investigation Gathers Steam: Taro Pharmaceuticals Agrees to Pay DOJ Total of $419 Million

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The DOJ Antitrust Division’s multi-year criminal cartel investigation of the generic pharmaceutical industry is gaining steam.  The latest company to settle is Taro Pharmaceuticals which agreed to enter a deferred prosecution...more

The Volkov Law Group

Bumble Bee CEO Convicted of Participating in Price-Fixing Conspiracy

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Global companies are paying greater attention to criminal antitrust risks – and with good reason.  We often dwell on the impact to a company of a major FCPA investigation.  A global criminal antitrust investigation often in...more

Hogan Lovells

Two key Brazilian regulators have entered into a cooperation agreement to fight transnational corruption and cartels

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The Administrative Council for Economic Defense (CADE) and the Ministry of Transparency, Supervision and Comptroller-General (CGU) have entered into a cooperation agreement to fight transnational corruption and cartels. ...more

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