President Trump’s February 10, 2025 Executive Order pausing Foreign Corrupt Practices Act (FCPA) enforcement and ordering an overhaul of FCPA policy marks a significant shift by the Department of Justice (DOJ), at least in...more
2/13/2025
/ Anti-Corruption ,
Attorney General ,
Bribery ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Reform ,
Trump Administration
On February 5, 2025, the US Department of Justice (DOJ) issued two memoranda, General Policy Regarding Charging, Plea Negotiations, and Sentencing and Total Elimination of Cartels and Transnational Criminal Organizations,...more
2/10/2025
/ Anti-Bribery ,
Anti-Money Laundering ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Enforcement Priorities ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Immigration Enforcement ,
Immigration Reform ,
National Security ,
Trump Administration
On January 16, 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule prohibiting the sale or import into the United States of passenger vehicles containing certain hardware or...more
1/29/2025
/ Automotive Industry ,
Bureau of Industry and Security (BIS) ,
China ,
Connected Cars ,
Cybersecurity ,
Export Controls ,
Final Rules ,
Hong Kong ,
Macau ,
National Security ,
OEM ,
Regulatory Agenda ,
Russia ,
Supply Chain ,
Trump Administration ,
U.S. Commerce Department
On January 10, 2025, the Biden Administration issued a broad sanctions package targeting the Russian energy sector, 10 days in advance of the transition to the incoming Trump Administration. The new sanctions also added two...more
1/14/2025
/ Biden Administration ,
Blocked Person ,
Department of Energy (DOE) ,
Economic Sanctions ,
Energy Sector ,
Enforcement Actions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
U.S. Treasury ,
UK
Proposed rule would create new prohibitions on transactions of sensitive personal data and government-related data -
The Department of Justice (DOJ) has proposed a new rule aimed at preventing access of China and other...more
Last Monday, the Department of Justice (the DOJ or the Department) announced significant updates to the DOJ Criminal Division’s Evaluation of Corporate Compliance Programs (ECCP). These updates discuss, for the first time,...more
The measure also harmonizes Russia sanctions rules with allies, and intensifies penalties against Iran -
The National Security Act, 2024 (Pub. L No 118-50) was enacted on April 24, 2024. In addition to the Act’s provisions...more
4/29/2024
/ China ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
Iran ,
National Security ,
Regulatory Agenda ,
Regulatory Reform ,
Russia ,
Sanction Violations ,
Statute of Limitations ,
Trade Policy ,
UK
The Department of Justice has announced yet another pilot program, adding to their “mix of carrots and sticks” designed “to promote responsible corporate citizenship.” The new whistleblower pilot program, which is still under...more
3/25/2024
/ Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Extortion ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
Contemporaneous with the European Union’s adoption of its 13th package of Russia sanctions, on February 23, 2024, the United States imposed sanctions against nearly 500 targets in continued response to Russia’s aggression...more
2/27/2024
/ Biden Administration ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Federal Procurement Systems ,
Financial Institutions ,
Financial Transactions ,
FinTech ,
Foreign Policy ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Payment Systems ,
Russia ,
Russian Military Procurement ,
SDN List ,
Ukraine ,
US State Departments
“Call us before we call you.” With this message, on January 10, 2024, the Southern District of New York announced the SDNY Whistleblower Pilot Program (Pilot Program), which seeks to encourage individual participants in...more
1/25/2024
/ Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Non-Prosecution Agreements ,
Pilot Programs ,
Voluntary Disclosure ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
Immediately following the October 7 attack by Hamas on Israel, the United States Financial Crimes Enforcement Network (FinCEN) announced the creation of the Counter Terrorist Financing Taskforce— Israel (CTFTI)—a coalition of...more
On October 4, 2023, US Deputy Attorney General (DAG) Lisa Monaco announced that the US Department of Justice (DOJ) is adopting a new Mergers & Acquisitions Safe Harbor Policy, incentivizing companies to voluntarily disclose...more
10/10/2023
/ Acquisitions ,
Antitrust Division ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Due Diligence ,
Mergers ,
Policies and Procedures ,
Safe Harbors ,
Voluntary Disclosure