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National Security Anti-Corruption Corruption

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

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

A&O Shearman

DOJ releases new FCPA enforcement guidelines

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On June 9, 2025, the U.S. Department of Justice (DOJ) released new guidelines for investigating and enforcing the Foreign Corrupt Practices Act (FCPA), in response to President Trump's February 10, 2025 Executive Order 14209...more

Alston & Bird

FCPA Pause, We Hardly Knew Ye: The DOJ Issues New FCPA Enforcement Guidance

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Our White Collar, Government & Internal Investigations Team analyzes new guidance from the Department of Justice that signals continued—and potentially heightened—enforcement of the Foreign Corrupt Practices Act....more

Arnall Golden Gregory LLP

DOJ’s New FCPA Guidelines Shifts Enforcement Priorities to Focus on National Security and Economic Competitiveness

On June 9, 2025, the U.S. Department of Justice released a memorandum titled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA),” formalizing an anticipated realignment of federal...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

Lowenstein Sandler LLP

The End of 180 Days of Uncertainty? DOJ Closes Current FCPA Investigations, Issues New Guidelines for FCPA Enforcement

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On June 9, Deputy Attorney General Todd Blanche issued a memorandum (the Memorandum) outlining revised guidelines for investigation and enforcement of the Foreign Corrupt Practices Act (FCPA). The U.S. Department of Justice...more

Thomas Fox - Compliance Evangelist

SBR-Author’s Podcast: The Unseen Life of an Undercover Agent: A Conversation with Charlie Spillers

Welcome to the SBR-Authors Podcast! In this podcast series, Host Tom Fox visits with authors in the compliance arena and beyond. Today, Tom is joined by Charlie Spillers, a former federal prosecutor, undercover agent, and...more

Wiley Rein LLP

[Podcast] Peeling Back the Bruising History of the Banana Trade

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Join hosts Diana Shaw and Tatiana Sainati as they explore the fascinating and dark history of the banana trade in the latest episode of Wicked Coin. From the entrepreneurial spirit of Minor Cooper Keith in the late 1800s to...more

Foley Hoag LLP

Trump Administration Pauses FCPA Enforcement – Why Compliance Is Still Critical

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On February 10, 2025, President Trump issued an executive order (EO) directing Attorney General Pam Bondi to effectively pause the Justice Department’s enforcement of the Foreign Corrupt Practices Act (FCPA). This was the...more

Wiley Rein LLP

[Podcast] The Iron Fist of General Sani Abacha, Nigeria's Ruthless Dictator

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Join hosts Tatiana Sainati and Diana Shaw as they delve into the gripping story of General Sani Abacha, the Nigerian dictator who embezzled billions of dollars and ruled with an iron fist from 1993 to 1998. Known for his...more

Snell & Wilmer

Reevaluating the Foreign Corrupt Practices Act Enforcement: A New Paradigm

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On February 10, 2025, President Trump signed an Executive Order (E.O.) directing a shift in the enforcement of the Foreign Corrupt Practices Act (FCPA). The order effectively pauses new FCPA investigations and enforcement...more

The Volkov Law Group

New FCPA Guidance — What to Expect (Part IV of V)

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As we continue through the maze of Executive Orders and new Guidance, which is expected in 180 days, the questions surrounding FCPA enforcement are swirling.  In some respects, we have had a preview.  It is hard to know what...more

DLA Piper

President Trump’s Executive Order Pauses FCPA Enforcement Pending Attorney General Review

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On February 10, 2025, President Donald Trump signed an Executive Order (EO) directing Attorney General (AG) Pam Bondi to pause enforcement of the Foreign Corrupt Practices Act (FCPA) until new enforcement guidelines and...more

Fox Rothschild LLP

Trump Executive Order Pauses FCPA Enforcement

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Raising questions about the future of U.S. anti-corruption policy, President Trump has temporarily paused enforcement of the Foreign Corrupt Practices Act (FCPA),. An Executive Order (EO) signed on Feb. 10, 2025, Pausing...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

Foley Hoag LLP - White Collar Law &...

AG Bondi Overhauls FCPA Enforcement in Day 1 Memo

On February 5, 2025, on her first day in office, U.S. Attorney General Pam Bondi issued fourteen memos outlining new policies for the U.S. Department of Justice (“DOJ”) in a broad range of enforcement arenas. Among these Day...more

Ballard Spahr LLP

CTA Reporting Requirements Blocked Again

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It’s hard to keep track of the status of reporting obligations under the Corporate Transparency Act (CTA) these days, but in a second ruling during the holiday week, a court blocked the filing requirement again. ...more

Dickinson Wright

Fifth Circuit Reinstates CTA Injunction, FinCEN Still Accepting Voluntary Filings

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In a surprising reversal, on December 26, 2024, a panel of the Fifth Circuit Court of Appeals issued an Order that vacated (effectively reversing) the same court’s order from December 23, 2024, and reinstated a lower court’s...more

Vorys, Sater, Seymour and Pease LLP

CTA UPDATE – Fifth Circuit Reinstates Nationwide Preliminary Injunction

On December 26, 2024, the Fifth Circuit Court of Appeals reinstated the nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA) in the case of Texas Top Cop Shop, Inc., et al. v. Garland,...more

Hinshaw & Culbertson LLP

Yet Another Twist: Fifth Circuit Reinstates Nationwide Freeze on Enforcement of Corporate Transparency Act Filing Deadlines – What...

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Seventy-two hours after a motions panel of the U.S. Court of Appeals for the Fifth Circuit stayed the effect of a nationwide preliminary injunction imposed by a Texas federal district court blocking the reporting deadline for...more

DLA Piper

Fifth Circuit Vacates Stay of Corporate Transparency Act Injunction, Again Putting Deadlines on Hold

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On December 26, 2024, the US Court of Appeals for the Fifth Circuit vacated the stay entered by a motions panel days earlier, which would have allowed the government to enforce the Corporate Transparency Act (CTA) while it...more

Seyfarth Shaw LLP

The Saga Continues: Fifth Circuit Court Reinstates Nationwide Injunction on CTA Pausing FinCEN’s Recently Announced Reporting...

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The Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury reset Corporate Transparency Act (CTA) reporting deadlines. However, on December 26, 2024, the Fifth Circuit Court of Appeals issued a...more

Pullman & Comley, LLC

Nationwide Injunction Halting Enforcement of CTA Reinstated

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The Fifth Circuit Court of Appeals has reinstated the stay with respect to Corporate Transparency Act (CTA) compliance which means that the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) is...more

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