Are You a Foreign Agent? [More with McGlinchey, Ep. 21
On February 5, 2025, US Attorney General (AG), Pam Bondi, issued a memorandum entitled Total Elimination of Cartels and Transnational Criminal Organizations, in which she provides new guidance to the Department of Justice...more
The breadth of the recently enacted FEPA presents pitfalls for U.S. companies dealing with foreign governments and state-owned entities requiring significant caution and effective compliance controls....more
You can always learn a lot from reviewing the underlying conduct to an FCPA enforcement action. Chief compliance officers can identify specific risk factors, mitigation steps and root causes for bribery schemes. ...more
Even with the absence of any major DOJ FCPA enforcement actions, DOJ issued an interesting FCPA Opinion Letter last week addressing application of the FCPA in circumstances where organizations face imminent serious bodily...more
This is the second post in this year’s series examining important trends and new development in white collar law and investigations. Our previous post discussed health care enforcement. Up next: trends in tax enforcement. ...more
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
On July 3, 2020, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) updated their 2012 joint guidance on the Foreign Corrupt Practices Act (“FCPA”) in the SEC and DOJ’s FCPA Resource Guide...more
Seyfarth Synopsis: No differently than companies doing business overseas—especially in high-risk markets—American colleges and universities who do business overseas face real risks of violating the Foreign Corrupt Practices...more