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
2/12/2025
/ Anti-Corruption ,
Cartels ,
Compliance ,
Corporate Counsel ,
Corporate Governance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Guidance ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Risk Management ,
Significant Transnational Criminal Organization ,
White Collar Crimes
On February 5, 2025, U.S. Attorney General Pam Bondi issued a series of fourteen policy memoranda directed to all employees of the U.S. Department of Justice (“DOJ”). Two are particularly likely to impact companies and higher...more
On December 22, 2023, President Biden signed into law the landmark, bipartisan Foreign Extortion Prevention Act (the FEPA), as part of the National Defense Authorization Act. Closing a gap in U.S. anti-corruption laws, the...more
On April 5, the U.S. Treasury Department's Office of Foreign Assets Control (“OFAC”) in the U.S. Department of the Treasury named Genesis Market to OFAC’s Specially Designated Nationals List (“SDN List”). Genesis Market is...more
4/27/2023
/ Cryptocurrency ,
Cyber Crimes ,
Cyber Threats ,
Dark Web ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
FBI ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Online Platforms ,
Russia ,
SDN List ,
U.S. Treasury
On June 3, 2021, President Biden issued his first National Security Study Memorandum, announcing that “countering corruption [is] a core United States national security interest.” It describes corruption as a threat to our...more
In what may be the beginning of a wave of enforcement actions, the Justice Department charged an organization and its leadership with dual healthcare and securities fraud charges. The prosecution underscores the risks facing...more
On March 25, 2020, the U.S. Senate passed a $2 trillion federal stimulus package (the largest in U.S. history) by an historic 96-0 vote. The Bill now goes to the U.S. House of Representatives (vote expected Friday, March 27)...more
Former Alstom SA executive Lawrence Hoskins’s jury convictions under the Foreign Corrupt Practices Act (“FCPA”) were set aside on February 26, 2020, by Judge Janet Bond Arterton of the United States District Court for the...more
3/3/2020
/ Agency Relationship ,
Alstom ,
Bribery ,
Criminal Conspiracy ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Guilty Pleas ,
Indonesia ,
Jurisdiction ,
Money Laundering ,
Subsidiaries ,
White Collar Crimes
Lawrence Hoskins, a British citizen and former employee of French conglomerate Alstom SA, has been found guilty by a federal jury in Connecticut of 11 of 12 criminal charges, including six counts of violating the United...more
11/18/2019
/ Agency Relationship ,
Alstom ,
Bribery ,
Corporate Officers ,
Corruption ,
Criminal Conspiracy ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Guilty Pleas ,
Indonesia ,
Jurisdiction ,
Money Laundering ,
Subsidiaries ,
White Collar Crimes
So, your organization is about to resolve a criminal matter with the U.S. Department of Justice (DOJ), including agreement as to the appropriate monetary penalty, but it cannot pay that fine or penalty without shutting its...more
Institutions and organizations are increasingly expected to conduct a thorough, neutral investigation of allegations of impropriety, misuse of authority, and sexual harassment, among many other issues. No organization, public...more
Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more
4/28/2016
/ Alstom ,
Anti-Corruption ,
Avon ,
Brazil ,
Bribery ,
Compliance ,
Cooperation ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Egypt ,
Enforcement Actions ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Kuwait ,
Novartis ,
Remediation ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Serbia ,
Serious Fraud Office (SFO) ,
Turkey ,
UK ,
Voluntary Disclosure ,
Wells Fargo ,
White Collar Crimes
The U.S. Department of Justice (“DOJ”) Criminal Division yesterday announced that its Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit is conducting a one-year FCPA enforcement pilot program (“Program”). A company...more
4/7/2016
/ Compliance ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Disgorgement ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure
During recent speeches Deputy Attorney General Sally Yates and SEC Enforcement Division head Andrew Ceresney announced changes to the processes the DOJ and the SEC will use to decide if a company will receive “cooperation...more
Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more
11/2/2015
/ Bribery ,
Bristol-Myers Squibb ,
Broken Windows ,
China ,
Corporate Officers ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Hitachi ,
Ireland ,
Securities and Exchange Commission (SEC) ,
Siemens ,
Whistleblower Protection Policies ,
Yates Memorandum
Deepening a circuit split, the Seventh Circuit has joined the Fifth Circuit in rejecting the implied false certification theory of liability under the FCA. United States v. Sanford-Brown, Ltd., No. 14-2506 (7th Cir., June 8,...more
The Securities and Exchange Commission (“SEC”) has brought its first-ever enforcement action against a company for using language in confidentiality agreements that prohibits employees from speaking with the SEC without prior...more
The attorney-client privilege has long protected attorney-client communications made during the course of an internal investigation. Upjohn Co. v. United States, 449 U.S. 383 (1983). Of course, the privilege encourages “full...more
Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more
Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more