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Practical Tips for Companies Following President Trump’s Pause on FCPA Enforcement

Since the President signed the February 10, 2025 Executive Order (Order) pausing enforcement of the Foreign Corrupt Practices Act (FCPA) (Client Alert: President Trump issues Executive Order “Pausing Foreign Corrupt Practices...more

Major Shift on Foreign Corrupt Practices Act: Trump Signs EO Pausing Enforcement

Last night, in a move with wide-ranging implications for American companies doing business abroad, President Trump issued an executive order (Order) temporarily halting enforcement of the Foreign Corrupt Practices Act (FCPA)....more

State Attorneys General Poised to Crack Down On Price Gouging Amid Market Pressure

This past Thursday, New York Attorney General Letitia James issued a warning to businesses against price gouging for eggs and poultry. The current bird flu outbreak began in March 2024 but has become a topic of increasing...more

Trump Tariffs on Canada, Mexico, and China

On February 1, 2025, the Trump Administration imposed long-expected tariffs on imports from Canada, Mexico, and China through the issuance of three executive orders (“EOs”). While some recent reporting suggested that...more

Trump Administration Tariff Regime: Uncertainty and Expectations

As he enters his second week in office, President Donald Trump is forecasting a desire to implement a muscular trade policy leaning heavily on the imposition of tariffs—potentially on a global basis—as a means of extracting...more

OFAC Enforcement Action Targets Non-U.S. Business Purchasing Services From North Korean Firm

On June 26, Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of an enforcement action against an Italian animation company that violated OFAC’s sanctions on North Korea. The enforcement action...more

Disruptive Technology Strike Force Announces Its First Declination to Prosecute Under the National Security Division’s Voluntary...

On May 22, 2024, the Department of Justice’s National Security Division (“NSD”) announced its first declination of prosecution for a company under the voluntary self-disclosure program established by the National Security...more

G7+ Coalition Issues Alert on Russian Oil Price Cap Evasion Methods and How to Report Violations

On February 1, 2024, the G7+ Coalition (consisting of the G7, the European Union, and Australia) published an Oil Price Cap (OPC) Compliance and Enforcement Alert (the “Alert”), identifying notable OPC evasion methods and...more

Disruptive Technology Strike Force Continues Focus on Trade Secret Theft, Export Control Enforcement

The Disruptive Technology Strike Force hosted a summit on Feb. 7-8, 2024, in Phoenix, Arizona, to commemorate its one-year anniversary. The Strike Force is an interagency law enforcement effort aimed at preventing...more

BIS Continues Enforcement Policy Ramp-Up

On January 16, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to incentivize voluntary self-disclosure (“VSD”) of possible violations of the Export Administration...more

Recent Sanctions Enforcement Actions Demonstrate Importance of  Incorporating All Available Data into Screening

For U.S. businesses, sanctions compliance has never been more challenging or more important. The U.S. has responded to Russia’s invasion of Ukraine with a broad range of sanctions targeting the Russian government, its...more

California Climate Accountability Package Poised to Disrupt

During the week of September 11, 2023, the California Legislature passed a series of bills known collectively as the “California Climate Accountability Package” (“CCAP”). The CCAP is comprised of three bills: S.B. 252...more

Departments of Justice, Commerce and Treasury Issue Tri-Seal Compliance Note on Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the U.S. Department of Justice’s National Security Division, U.S. Department of Commerce’s Bureau of Industry and Security, and U.S. Department of the Treasury’s Office of Foreign Assets Control issued a...more

Disruptive Technology Strike Force Initiates Federal Prosecutions Targeting Trade Secret Theft

In early 2023, the U.S. Department of Justice and U.S. Department of Commerce launched the Disruptive Technology Strike Force to target illicit actors, strengthen supply chains and protect critical technology assets from...more

U.S. Department of Justice and Partners Increasing Enforcement of Sanctions and Export Controls

It has been a little more than a year since Russia’s invasion of Ukraine, and the war continues to rage. In an effort to deter the Russian government and weaken its military capabilities, the United States has imposed...more

FinCEN Alert Highlights Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites and Their Proxies

The Financial Crimes Enforcement Network (FinCEN) has recently issued an alert cautioning all financial institutions regarding potential investments in the U.S. commercial real estate (CRE) sector, by or on behalf of...more

Consumer Watchdog Calls on California AG to Investigate Rising Energy Prices

On Jan. 18, 2023, a consumer advocacy group issued a letter urging the California Attorney General’s Office to initiate an investigation into rising natural gas prices in the state. If the group’s campaign gains traction,...more

Commerce Department Releases Preliminary Findings on Chinese Solar Manufacturers’ Alleged Circumvention

On Dec. 2, 2022, the U.S. Department of Commerce (DOC) released its preliminary determinations over the ongoing investigation into whether solar cells and modules imported from certain Southeast Asian countries were...more

Brazilian Airline to Pay Millions in Coordinated Foreign Bribery Resolution

On September 15, 2022, GOL Linhas Aéreas Inteligentes S.A. (GOL), Brazil’s second largest domestic airline, resolved long-running parallel investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange...more

Proposed Federal Rule Signals Remote Form I-9 Inspection of Employee Documents Will Likely Become Permanent Option

On August 18, 2022, the Department of Homeland Security (DHS) published a Proposed Rule titled Optional Alternatives to the Physical Document Examination Associated With Employment Eligibility Verification (Form I-9). The...more

Less is More? DOJ Signals Shift to More Targeted Evidence Collection

For a corporation receiving a grand jury subpoena, the most difficult (and expensive) part of a U.S. Department of Justice (DOJ) inquiry is often sifting through corporate data to find relevant material. That is proving to be...more

DOJ and SEC Kick Off the Second Quarter with Major FCPA Settlement with International Waste Management Company

On April 20, 2022, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) separately announced that Stericycle Inc. (Stericycle), an international waste management company headquartered in Lake...more

New Revelations in Ukraine Lead to Tightening Global Sanctions

As the world watched in horror over the atrocities occurring in the war zones of Ukraine this week, global leaders re-doubled their efforts to bring increasing sanctions pressure to bear on Russian industry, the Russian...more

Western Companies Starting to Feel Impact of Russian Sanctions

As we approach the thirty day mark since the United States, and other Western countries began imposing a series of rigorous sanctions on the Russian economy and key components thereof, we are starting to see real evidence of...more

FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions including Use of Virtual...

The Financial Crimes Enforcement Network (FinCEN) has issued an alert encouraging all financial institutions to be “vigilant” against efforts by their customers to evade recent sanctions and other restrictions imposed by the...more

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