On February 10, 2025, President Donald J. Trump signed an Executive Order pausing enforcement of the Foreign Corrupt Practices Act ("FCPA") by the U.S. Department of Justice ("DOJ") for 180 days and ordering Attorney General...more
The recently created SDNY Whistleblower Pilot Program encourages individuals to self-disclose certain criminal conduct and cooperate in resulting investigations and prosecutions.
...more
2/8/2024
/ Anti-Corruption ,
Corruption ,
Criminal Investigations ,
Criminal Liability ,
Department of Justice (DOJ) ,
New York ,
Non-Prosecution Agreements ,
Pilot Programs ,
Self-Disclosure Requirements ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
Foreign Corrupt Practices Act (“FCPA”) enforcement continues to slowly rebound from pre-pandemic levels. In 2023, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) resolved 13 corporate FCPA...more
Foreign Corrupt Practices Act (“FCPA”) enforcement has yet to rebound from the immediate pre-pandemic period. In 2022, DOJ and SEC resolved eight corporate FCPA matters for $878 million, including four resolutions coordinated...more
3/3/2023
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Bribery ,
Compliance ,
Corporate Counsel ,
Corporate Crimes ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
Securities and Exchange Commission (SEC)
The Biden administration took office in January 2021, announcing aggressive and sweeping anticorruption initiatives to tackle corruption around the world, labeling corruption a national security priority, and signaling a...more
1/28/2022
/ Anti-Corruption ,
Biden Administration ,
Compliance ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Securities and Exchange Commission (SEC) ,
Whistleblowers ,
White Collar Crimes
On May 19, 2021, the SEC announced an award of more than $28 million to a whistleblower whose tip led the SEC and the DOJ to reach a combined $281 million FCPA settlement with a U.S.-based manufacturer of electronic systems...more
6/23/2021
/ Anti-Corruption ,
Biden Administration ,
Compliance Management Systems ,
Corruption ,
Enforcement Actions ,
Enforcement Guidance ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Reporting ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
In 2020, the biggest Foreign Corrupt Practices Act (“FCPA”) headline was the record-shattering global anticorruption enforcement fines and penalties collected by foreign regulators in actions involving a coordinated FCPA...more
1/13/2021
/ Anti-Corruption ,
Biden Administration ,
Bribery ,
Compliance ,
Corporate Counsel ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
The Situation: On July 3, 2020, the Department of Justice ("DOJ") and the Securities and Exchange Commission ("SEC") published a second edition of the "Resource Guide to the Foreign Corrupt Practices Act," almost eight years...more
7/14/2020
/ Anti-Bribery ,
Anti-Corruption ,
Civil Forfeiture ,
Compliance ,
Controlled Foreign Corporations ,
Department of Justice (DOJ) ,
Disgorgement ,
FCPA Corporate Enforcement Policy (CEP) ,
FCPA Resource Guide ,
Foreign Corrupt Practices Act (FCPA) ,
Kokesh v SEC ,
Liu v Securities and Exchange Commission ,
Securities and Exchange Commission (SEC)
The Situation: The Department of Justice ("DOJ") has updated its "Evaluation of Corporate Compliance Programs" guidance for prosecutors.
The Result: The updates provide additional insights into the factors the DOJ is...more
6/11/2020
/ Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Corporate Governance ,
Department of Justice (DOJ) ,
Internal Controls ,
Risk Assessment ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Strategic Planning ,
White Collar Crimes
Welcome to the 2019 edition of the Jones Day Anti-Corruption Regulation Survey of Select Countries. Since the 2017–2018 edition of this Survey, there has continued to be an increasing awareness among multinational companies...more
11/6/2019
/ Anti-Bribery ,
Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Corporate Counsel ,
Corporate Governance ,
Corporate Management ,
Due Diligence ,
Risk Management ,
White Collar Crimes
Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more
4/18/2018
/ Anti-Bribery ,
Anti-Corruption ,
Chief Compliance Officers ,
Corporate Counsel ,
Corporate Governance ,
Corporate Liability ,
Corruption ,
Department of Justice (DOJ) ,
Due Diligence ,
Ethical Standards ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Government Officials ,
Internal Audit Functions ,
Internal Controls ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Third-Party Risk ,
White Collar Crimes
The United States Department of Justice, the U.S. Securities and Exchange Commission, and non-U.S. governments and agencies have recently emphasized their continued commitments to pursuing both corporate and individual...more
2/1/2018
/ Anti-Corruption ,
Board of Directors ,
Chief Compliance Officers ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Due Diligence ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Investigations ,
Policies and Procedures ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
The Situation: Companies that learn of Foreign Corrupt Practices Act ("FCPA") violations by employees or agents are faced with significant uncertainty as to whether the benefits and risks of self-disclosing the conduct to the...more
12/5/2017
/ Anti-Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Remediation ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Voluntary Disclosure ,
White Collar Crimes
On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more
3/2/2017
/ Anti-Corruption ,
Board of Directors ,
Compliance ,
Confidential Communications ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Internal Investigations ,
New Guidance ,
OECD ,
Policies and Procedures ,
Popular ,
Publicly-Traded Companies ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Senior Managers ,
Third-Party Relationships ,
Training