The executive order halts new and existing foreign bribery investigations — but enforcement risk in the UK and Europe remains.
On February 10, 2025, President Trump issued an executive order titled “Pausing Foreign...more
2/14/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Misconduct ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
EU ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
UK
Companies in the US and around the world should consider their potential for UK exposure and assess their compliance programmes in light of that risk.
On 1 September 2025, the UK will implement a new corporate criminal...more
2/13/2025
/ Corporate Governance ,
Corporate Liability ,
Corporate Misconduct ,
Criminal Prosecution ,
Enforcement Actions ,
Failure to Prevent ,
Fraud ,
Fraud Prevention ,
Multinationals ,
Risk Management ,
UK ,
White Collar Crimes
Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors.
In a speech at Georgetown University Law Center on...more
2/7/2023
/ Bribery ,
Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Corruption ,
Declination ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
Updated DOJ policies will continue to focus on individual accountability and corporate recidivism, while aiming to provide additional incentives for voluntary self-reporting, foster greater transparency on use of monitors,...more
9/28/2022
/ Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Corporate Officers ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Personal Liability ,
Voluntary Disclosure
The priorities will impact non-US companies who may face a US DOJ with a renewed emphasis on combating corporate crime.
In a recent speech that has garnered significant attention, the Deputy Attorney General of the...more
11/5/2021
/ Biden Administration ,
Compliance ,
Compliance Monitoring ,
Corporate Crimes ,
Corporate Culture ,
Corporate Misconduct ,
Corporate Monitoring ,
Criminal Prosecution ,
Cross Border Privacy Rules (CBPR) ,
Cross-Border ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corporations ,
Foreign Corrupt Practices Act (FCPA) ,
Non-Prosecution Agreements ,
Personal Liability ,
UK ,
White Collar Crimes
The DOJ’s recently updated guidance poses helpful questions for UK corporates evaluating the effectiveness of their internal compliance programmes.
It is well known that a corporate’s failure to prevent offences can be...more