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FCPA 2022 Year in Review

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

First Corporate Anti-Terrorism Act Prosecution Marks Expansion of U.S. Counterterrorism Efforts

In Short - The Situation: In October 2022, the U.S. Department of Justice ("DOJ" or "Department") announced a guilty plea in its first-ever corporate "material support" prosecution under 18 U.S.C. § 2339B of the...more

First Circuit Rejects "Predominantly Foreign" Exception to Morrison’s "Domestic Transactions" Test

Two circuit courts have now rejected the Second Circuit's "predominantly foreign" exception to Morrison's "domestic transactions" test, which raises the prospect of inconsistent decisions and increases the likelihood of...more

FCPA 2020 Year in Review

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

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