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DOJ Announces Major Changes to Corporate Criminal Enforcement Policies

In a keynote address to the American Bar Association’s 2021 National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa O. Monaco outlined major changes to the U.S. Department of Justice’s (DOJ) priorities...more

Biden Administration Identifies Global Corruption as a National Security Issue

In a move long expected by this firm and other experts in this area, on 3 June 2021, the Biden administration issued a policy statement tethering global anti-corruption efforts as vital to the country’s national security...more

DOJ Releases Its First FCPA Advisory Opinion Since 2014—What You Need to Know About the FCPA Advisory Opinion Process

For the first time since 2014, the Department of Justice’s (DOJ) Foreign Corrupt Practices Act (FCPA) Unit has issued an opinion responding to a request for advice on compliance with the anti-bribery provisions of the FCPA. ...more

DOJ and SEC Issue First Major Update to FCPA Resource Guide Since 2012: What You Need to Know

INTRODUCTION - On 3 July 2020, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) released the second edition of the Resource Guide to the U.S. Foreign Corrupt Practices Act (Resource...more

DOJ Emphasizes Data-Driven Approach to Monitoring and Importance of Culture in Latest Adjustments to Corporate Compliance Program...

I. INTRODUCTION - On 1 June 2020, the Criminal Division of the U.S. Department of Justice (DOJ) updated a critical guidance document, the “Evaluation of Corporate Compliance Programs” memorandum (“Guidance”), providing...more

COVID-19: Senior Officials Comment on the Current State of Enforcement, Expectations, and Context Considerations During the...

On 20 May 2020, as part of the American Conference Institute’s Anti-Corruption Global Series, senior federal law enforcement officials described how their respective agencies are operating in light of the global pandemic and...more

COVID-19: Planning for Wave of CARES Act Enforcement for Aviation Industry

As detailed in prior alerts, the Coronavirus Aid, Relief, and Economic Security Act of 2020 (the “CARES Act” or the “Act”) provides, among other things, financial assistance to the aviation industry through payroll support...more

DOJ Revises Corporate Compliance Guidance Calling Attention to Three Areas Where Most Companies Fall Short: Risk Assessments,...

On April 30, 2019, the U.S. Department of Justice (“DOJ”) Criminal Division revised its Evaluation of Corporate Compliance Programs Guidance Document (the “2019 Guidance”) to assist prosecutors in evaluating the effectiveness...more

Takeaways from the 34th International Conference on the Foreign Corrupt Practices Act

At the 34th International Conference on the Foreign Corrupt Practices Act held last week in Washington, D.C., industry executives, members of the defense bar, and regulators examined developments in the enforcement of the...more

The New Faces of FCPA Enforcement: The Transition to a Sessions-Clayton Enforcement Regime Is Unlikely to Result in Drastic...

Now that the Trump administration has passed its first 100 days, some additional insights are available with respect to how the administration plans to enforce anti-corruption laws, including the Foreign Corrupt Practices Act...more

Sapin II - France’s War on Corruption

In July 2015, Michel Sapin, the French Minister of Finance, summarized his proposals for a new French law prohibiting corruption and seeking “transparency in economic life”. That law, modeled after the U.S. Foreign Corrupt...more

FCPA Enforcement Under Trump: Don’t Call Off the Cavalry Just Yet

Despite President-elect Donald Trump’s past negative comments about the Foreign Corrupt Practices Act (“FCPA”), companies should continue to take FCPA compliance seriously and employ best practices. Indeed, ethical business...more

Singapore Gets Serious About Money Laundering

The fallout from the scandal surrounding 1MDB and the Singapore-based banks that facilitated the flow of funds to and from those connected with the Malaysia-backed sovereign fund shows no signs of abating, as the recent...more

The First Ninety Days of the FCPA Unit’s Pilot Program

On April 5, 2016, the Department of Justice (“DOJ”) introduced a yearlong “Pilot Program” to guide the conduct of investigations and prosecutions pursuant to the Foreign Corrupt Practices Act (“FCPA”). Announced by Assistant...more

A New Sheriff In Town: The Monetary Authority of Singapore Creates New Anti-Money Laundering And Enforcement Departments

On 13 June 2016, the Monetary Authority of Singapore (“MAS”) announced that it will create dedicated Anti-Money Laundering (“AML”) and Enforcement departments, including a special supervisory team to be established to monitor...more

Singapore’s Banking Secrets - Not So Secret Anymore

Since 2008, the U.S. Government has largely focused its enforcement actions against Swiss banks that may have assisted U.S. taxpayers in evading federal taxes. In August 2013, the Department of Justice (“DOJ”) introduced the...more

The SEC Is Actively Encouraging Whistleblowers: How Should You Respond?

In the Securities and Exchange Commission’s (“SEC”) 2015 annual report to Congress on the Dodd-Frank Whistleblower Program, dated November 16, 2015, Sean McKessy, the chief of the Office of the Whistleblower (“OWB”), stated...more

DOJ and SEC Representatives Tackle Pressing Anti-Corruption Issues in 2014

On March 20th and 21st, U.S. regulators, practioners, and other anti-corruption industry professionals gathered in Washington, D.C. for the Second Annual Global Anti-Corruption Congress. The Congress featured speakers,...more

What Do Federal Authorities Expect of Companies Subject to the FCPA?

In mid-November 2012, federal authorities released their much-anticipated ”FCPA: A Resource Guide to the U.S. Foreign Corrupt Practices Act,” prepared jointly by the Justice Department’s Criminal Division and the Enforcement...more

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