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White Collar Crimes Executive Orders 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

Baker Donelson

Update: DOJ Issues Guidelines for Protectionist FCPA Enforcement

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In February, the White House issued an Executive Order "pausing" Foreign Corrupt Practices Act (FCPA) enforcement for 180 days, to "further American economic and national security."1 On June 9, Deputy Attorney General Todd...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

Hogan Lovells

FCPA reloaded: The DOJ “unpauses” enforcement – But is it a new level?

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On June 9, 2025, Deputy Attorney General Todd Blanche issued revised enforcement guidelines for the Foreign Corrupt Practices Act (FCPA), officially ending the FCPA enforcement pause that Executive Order 14209 (EO) instituted...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

Skadden, Arps, Slate, Meagher & Flom LLP

Deputy Attorney General Issues FCPA Guidelines Resuming Limited Enforcement

Key Points - - The U.S. Department of Justice (DOJ) will resume investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA), prioritizing, in part, FCPA actions involving cartels and transnational...more

Ballard Spahr LLP

Focused FCPA Enforcement: Emphasizing Security and Strategic Interests

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On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the DAG memorandum) updating the Department of Justice’s (DOJ) enforcement guidelines for the Foreign Corrupt Practices Act (FCPA) in accordance with...more

Baker Botts L.L.P.

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

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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

Carlton Fields

Shifting Priorities in White Collar Enforcement: May 2025 DOJ Memo and What It Means for Companies

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On May 12, 2025, the Department of Justice (DOJ) Criminal Division announced significant changes in its policies on investigating and prosecuting white collar crime, including a shift in focus toward several areas deemed to...more

Stikeman Elliott LLP

Foreign Bribery: The Bottom Line is that It’s Still Illegal Under Canadian Law

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It remains illegal under the Canadian Corruption of Foreign Public Officials Act (“CFPOA”) to bribe foreign officials. While this statement may be self-evident, recent developments south of the border prompt this reminder to...more

Vedder Price

Changed Focus of FCPA Actions Under Trump Executive Order

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On February 5, 2025, newly appointed U.S. Attorney General Pam Bondi issued a memorandum titled “Total Elimination of Cartels and Transnational Criminal Organizations” (the February 5 Memorandum), which outlined a broad...more

Jenner & Block

Client Alert: The Trump Administration Calls for a Pause on New FCPA Enforcement, but Don’t Abandon Compliance Programs Just Yet

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In an executive order issued on February 10, 2025 (Executive Order), and a memorandum issued by Attorney General Pam Bondi regarding cartels and transnational criminal organizations on February 5, 2025 (Cartel Memo), the...more

Alston & Bird

Trump Administration Halts New FCPA Enforcement, Will Review Open Investigations

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In a move that sent shockwaves through the world of white collar corporate defense, President Trump has issued an Executive Order instructing the Attorney General to pause new FCPA enforcement subject to review existing FCPA...more

Skadden, Arps, Slate, Meagher & Flom LLP

Anti-Bribery and Corruption Risks Remain Despite FCPA Enforcement Pause

On February 10, 2025, President Donald Trump signed an executive order directing the U.S. attorney general, Pam Bondi, to pause Foreign Corrupt Practices Act (FCPA) actions for 180 days until she issues revised FCPA...more

Holland & Knight LLP

FCPA Enforcement on Pause Per Executive Order

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Just over two months ago, the Kansas City Chiefs were still two-time defending Super Bowl champions, Luka Doncic was a Dallas Maverick, and the U.S. Department of Justice's (DOJ) Foreign Corrupt Practices Act (FCPA) Unit was...more

Lowenstein Sandler LLP

Long Live the FCPA?

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The Trump administration has taken significant action this week to overhaul the executive branch’s long-standing policy toward the prosecution of white collar offenses. First, a memo issued by newly confirmed U.S. Attorney...more

Morrison & Foerster LLP

FCPA Enforcement Under the Second Trump Administration

Since its enactment in 1977, the FCPA has been the primary legal mechanism in the United States for preventing and punishing corrupt business practices around the world. At a high-level, the FCPA applies to both domestic and...more

Dorsey & Whitney LLP

Should Your Company Shut Down Its Anti-Corruption Compliance Program and Start Paying Bribes? Here Are a Few Reasons to Think...

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On February 10, 2025, President Trump issued a new Executive Order (“EO”) titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” This EO comes on the tail of Attorney...more

WilmerHale

President Trump and Attorney General Bondi Announce Significant Shift in FCPA and Other Corporate Enforcement Priorities

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Soon after being sworn in, President Trump issued Executive Orders identifying top administration priorities: combating illegal immigration, drug cartels, and unlawful DEI practices. Taking a similar tack, on her first day in...more

Latham & Watkins LLP

President Trump Issues Executive Order Pausing Foreign Corrupt Practices Act Enforcement at DOJ

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The order pauses new FCPA criminal cases, directs review of existing cases, and leaves open several questions, including implications for specific business sectors and civil enforcement....more

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