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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

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

Baker Botts L.L.P.

Back from the Dead? Takeaways from US DOJ’s New Guidelines for FCPA Investigations and Enforcement

Baker Botts L.L.P. on

On June 9, 2025, the Deputy Attorney General of the United States Department of Justice issued “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (the “Memorandum”). The Memorandum...more

DLA Piper

How Argentina Reached a Turning Point for Corporate Accountability and Compliance in 2024

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In 2024, Argentina experienced a pivotal moment in corporate law enforcement with the first significant application of its Corporate Criminal Liability Law No. 27,401, enacted in 2018. This law holds private entities...more

The Volkov Law Group

McKinsey Company Pays $122 Million to Resolve FCPA Violations in South Africa (Part I of III)

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On December 5, 2024, DOJ announced a settlement with McKinsey and Company for $122 million for bribes paid to South African government officials to secure valuable consulting contracts....more

Jones Day

Dutch Public Prosecution Office Publishes Rules on Self-Disclosure, Cooperation and Self-Investigation

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The Dutch Public Prosecution Office ("DPPO") has introduced a new policy (aanwijzing), effective 1 January 2025, outlining conditions and fine reductions for self-disclosure, cooperation and self-investigation in corporate...more

Estlund Law, P.A.

Turkey, Egypt: INTERPOL Member Countries Abusing Red Notices To Target Journalists

Estlund Law, P.A. on

Our last post detailed cases of member countries abusing or attempting to abuse INTERPOL to target specific journalists. Those cases are not at all unique; INTERPOL abuse by its member countries has been documented for years....more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger

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Recorded at our 2024 White-Collar Symposium held in Philadelphia last month, this special episode dives into the landscape of white-collar criminal prosecution from the perspectives of Bill Baroni and Jesse Eisinger. Both...more

Estlund Law, P.A.

Global Entry Cards, Visas, and Red Notices- Post 1 of 2

Estlund Law, P.A. on

In an increasingly globalized world, travel and international mobility are more essential than ever. Programs such as the United States’ Global Entry trusted traveler program, which expedite customs and immigration processes...more

Wiley Rein LLP

Wicked Coin: The "Fat Leonard" Scandal

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Power and corruption … two sides of a Wicked Coin. In this podcast, hosts Tatiana Sainati, co-chair of Wiley’s Global Disputes Practice, and Diana Shaw, a partner in Wiley’s White Collar & Government Investigations Practice...more

The Volkov Law Group

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

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The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination.  But even a declination comes with a requirement — the company has...more

The Volkov Law Group

Tracking FCPA Individual Enforcement

The Volkov Law Group on

While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more

Thomas Fox - Compliance Evangelist

Lessons on Ongoing Monitoring and Continuous Improvement from Star Trek: Spectre of the Gun

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Thomas Fox - Compliance Evangelist

The Foreign Corrupt Practices Handbook: Interview with the Authors

I recently spoke with the Foreign Corrupt Practices Act (FCPA) Handbook authors Robert Tarun and Peter Tomczak from Baker McKenzie for a two-part podcast episode. The depth of knowledge and experience in white-collar crime,...more

Jones Day

Raids by Asia-Pacific Enforcers Are on the Rise: A Guide to Being Prepared for When the Enforcer Comes Knocking

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The Development: After an interruption during the COVID-19 pandemic, authorities across the Asia-Pacific region have fully revived dawn raids....more

The Volkov Law Group

Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis

The Volkov Law Group on

Carlos Villagrán is the Director of Compliance at CMPC, a 100 years’ old Chilean-based holding company, one of the worldwide leading manufacturers of pulp, paper, packaging, personal care and other forest products. Carlos...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the...

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In a single decade, the prosecutions of those accused of white-collar crime underwent a radical transformation. This thought-provoking episode will take you back in time to explore the DOJ's approach in the early 2000s Enron...more

The Volkov Law Group

Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement

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On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ's FCPA Sweep against the industry.  Trafigura joined the list...more

Thomas Fox - Compliance Evangelist

DAG Monaco at ABA White Collar Conference: Self-Disclosure, Wanted Posters and AI

There were recently two significant speeches by Department of Justice (DOJ) officials at the American Bar Association National Institute on White Collar Crime. The first was by Deputy Attorney General Lisa Monaco. The second...more

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 3-the Discounted Fine

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more

The Volkov Law Group

Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm

The Volkov Law Group on

DOJ has promised an aggressive criminal corporate enforcement program against sanctions violators. The storm is coming and will arrive soon with a bang. There is no question that DOJ's enforcement initiative is coming -- it...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 2, the Need for Speed

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Latham & Watkins LLP

New SFO Director Sets Tone for Tenure

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Motivated by a “visceral reaction” to large-scale economic crime, Nick Ephgrave lays out vision for a bolder, more pragmatic, and more proactive agency. Whistleblowers, dawn raids, and cross-agency collaboration are all...more

Jones Day

SDNY Launches Whistleblower Pilot Program to Encourage Self-Disclosure of Criminal Conduct

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The recently created SDNY Whistleblower Pilot Program encourages individuals to self-disclose certain criminal conduct and cooperate in resulting investigations and prosecutions. ...more

Troutman Pepper Locke

Recent Fraud Settlements: DOJ Values Voluntary Self-Disclosure and Corporate Cooperation

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The Department of Justice’s (DOJ) conduct since announcing its February 22, 2023, Voluntary Self Disclosure (VSD) policy, demonstrates that the government continues to place a premium on corporate cooperation in both criminal...more

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