News & Analysis as of August 2, 2025

Fraud › FCPA Corporate Enforcement Policy (CEP)

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Fraud is the making of false representations or engaging in deceptive behavior in order to unlawfully secure financial or personal gain.

DOJ Criminal Division Revises Its Corporate Enforcement Policy, Monitor Selection Policy, and Whistleblower Award Program

Morrison & Foerster LLP on 6/2/2025

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (DOJ) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and Corporate Whistleblower Awards Pilot Program (Whistleblower...more

Another Declination from DOJ’s Criminal Division Emphasizes the Continued Focus on Voluntary Self-Disclosure in 2024

Mintz on 4/26/2024

Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more

DOJ Bolsters International Cooperation to Combat Corruption

Ballard Spahr LLP on 12/6/2023

Summary - The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...more

International Trade Enforcement Roundup – January 2023

Bass, Berry & Sims PLC on 2/8/2023

Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more

DOJ Announces Formal Expansion of Corporate Enforcement Policy to Incentivize More Self-Reporting

Cadwalader, Wickersham & Taft LLP on 1/20/2023

On January 17, 2023, Assistant Attorney General Kenneth Polite announced revisions to the Department of Justice (DOJ) Criminal Division’s Corporate Enforcement Policy (CEP), expanding the availability of a potential full...more

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