National Security, Foreign Corrupt Practices Act (FCPA), Cross-Border Transactions

DOJ Issues New Guidelines Narrowing FCPA Enforcement Scope

Porter Hedges LLP on 6/18/2025

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

National Security in the Age of Blockchain

Oberheiden P.C. on 9/26/2023

Blockchain presents unprecedented challenges around national security. This is true not only for the federal government, but also for businesses in the private sector. From cross-border transactions involving cryptocurrency...more

When to Press ‘Pause’ (and ‘Play’) in M&A: CFIUS and Trade Regulation Considerations

Morgan Lewis on 3/2/2023

While the longstanding review by the United States of cross-border investments for national security implications might sound like the same old song, several important developments in recent years should give investors and...more

Compliance measures to address sanctions enforcement: ‘the new FCPA’

American Conference Institute (ACI) on 7/12/2022

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

2021 Year in Review: FCPA

Goodwin on 2/4/2022

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

Administration's Anti-Corruption Efforts Likely to Yield Greater FCPA Enforcement in Latin America and Beyond

Womble Bond Dickinson on 8/25/2021

On June 3 of this year, the Biden Administration made plain its commitment to fighting corruption around the world, releasing a document identifying the fight against corruption “as an economic and national security priority”...more

Biden Administration Issues Directive for Revitalized Strategies to Combat Corruption and Financial Crime, Signaling Increased...

Herbert Smith Freehills Kramer on 6/9/2021

On June 3, 2021, President Biden issued the first National Security Study Memorandum of his presidency, in which he declared fighting corruption “a core United States national security interest.” The Memorandum sets out the...more

National Security › Foreign Corrupt Practices Act (FCPA) › Cross-Border Transactions