News & Analysis as of

Anti-Bribery Department of Justice (DOJ) Enforcement Actions

Seyfarth Shaw LLP

Navigating Trump’s FCPA Enforcement Pause: Strategic Recommendations for Corporate Leaders

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President Trump’s February 10th Executive Order (EO) titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security,” has introduced significant uncertainty into FCPA enforcement....more

Maynard Nexsen

Despite FCPA Enforcement Pause, Anti-Corruption Should Remain a Compliance Priority

Maynard Nexsen on

On February 10, 2025, President Donald J. Trump issued an Executive Order instructing the Department of Justice (DOJ) to temporarily pause Foreign Corrupt Practices Act (FCPA) enforcement and reconsider its enforcement...more

NAVEX

FCPA Enforcement Might Take a Pause – Your Compliance Needs Won’t

NAVEX on

Corporate compliance officers might feel like they’ve been put through the whirlwind lately, with the Trump Administration issuing one sweeping announcement about corporate enforcement after another. Except, remember what a...more

Seward & Kissel LLP

Pausing Bribery Prosecutions: What Companies Need to Know

Seward & Kissel LLP on

Last week President Trump signed an Executive Order pausing enforcement of the nation’s most robust anti-bribery statute, the Foreign Corrupt Practices Act (“FCPA”). The EO seeks a complete overhaul of the FCPA enforcement...more

Nelson Mullins Riley & Scarborough LLP

Bribers, Start Your Engines or Pump the Brakes?

Five Fast Reminders as Trump Pauses FCPA Enforcement - Late on February 10, 2025, President Trump issued an Executive Order (“EO”) instructing the Attorney General to pause Foreign Corrupt Practices Act (“FCPA”)...more

Eversheds Sutherland (US) LLP

New Department of Justice policy directives outline shift in enforcement priorities

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

Buchalter

Trump’s New Approach to the FCPA

Buchalter on

On February 5, 2025, US Attorney General (AG), Pam Bondi, issued a memorandum entitled Total Elimination of Cartels and Transnational Criminal Organizations, in which she provides new guidance to the Department of Justice...more

Morgan Lewis

Newly Confirmed AG Pam Bondi Issues Directive Limiting Scope of FCPA Enforcement

Morgan Lewis on

Newly Appointed US Attorney General Pam Bondi issued a directive shifting the focus of Foreign Corrupt Practices Act investigations and cases away from those that do not involve criminal operations of cartels and...more

Adams & Reese

International Compliance Digest – October 2024

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October was a robust month for compliance with agency actions and guidance concerning anti-boycott, forced labor, section 301 exclusions, outbound investment, and sanctions. The International Trade Commission also voted...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

WilmerHale on

Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

Littler

Robust Action Helps Recidivist Employer Reduce Penalty for Alleged Bribery in South Africa and Indonesia

Littler on

In the first major action of 2024, the Department of Justice (DOJ) announced it had entered into a three-year deferred prosecution agreement (DPA) with a publicly traded global software company for alleged violations of the...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Program - March 13th - 14th, Mexico City, Mexico

ACI’s Mexico Summit on Anti-Corruption & Compliance Programs returns on March 13-14, 2024 in Mexico City! Given the uncertainty with the looming Presidential election, as well as increased U.S. enforcement focus on Mexico...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 3: The Comeback

This week we are taking a deep dive into the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. In it, SAP agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) approximately...more

The Volkov Law Group

SAP’s Bribery Schemes — Systemic Corruption Around the Globe (Part II of III)

The Volkov Law Group on

When it comes to FCPA enforcement and expectations, DOJ has moved the goalposts.  Some would argue that DOJ has been consistent all along.  The truth, like most issues, lies somewhere between the extremes....more

The Volkov Law Group

DOJ and CFTC Close Out Slow FCPA Enforcement Year with $98 Million Resolution with Freepoint Commodities LLC (Part I of II)

The Volkov Law Group on

The Justice Department’s FCPA enforcement record for 2024 was slow.  This  trend was unexpected, contrary to my own predictions and of various other prognosticators.  It is hard to explain why this slowdown occurred....more

Alston & Bird

Expanding U.S. Prosecutors’ Anti-Corruption Toolkit: FEPA Is Signed into Law

Alston & Bird on

Signed into law on December 22, 2023, the Foreign Extortion Prevention Act (FEPA) signals a further focus by the U.S. government on anti-corruption enforcement. Our White Collar, Government & Internal Investigations Team...more

Littler

Proper Planning and Swift Action Can Help Employers Avoid Foreign Corrupt Practices Act Prosecution

Littler on

While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more

American Conference Institute (ACI)

[Event] 17th Forum on the Foreign Corrupt Practices Act - January 24th - 25th, Houston, TX

As the most anticipated gathering for the community in Texas and the region, don’t miss out on re-connecting with your peers and more! With the continued focus on FCPA compliance and the anticipated rise in enforcement,...more

American Conference Institute (ACI)

[Event] 18th Annual FCPA & Anti-Corruption for the Life Sciences Industry - May 10th - 11th, New York, NY

Hosted by American Conference Institute, the 18th Annual Conference on the FCPA & Anti-Corruption for the Life Sciences Industry returns for another exciting year with curated programming that shines a global spotlight on...more

Fisher Phillips

Deal of a Lifetime – or Jailtime and Fines? 5 Best Practices to Avoid Foreign Corrupt Practices Act Violations

Fisher Phillips on

One of your employees working overseas emails you with great news – they’re about to close a $50 million sale with a new customer. They tell you everything looks great, but there’s just one thing. The local political party...more

The Volkov Law Group

Ericsson Settles Breach of 2019 FCPA Deferred Prosecution Agreement: Agrees to Plead Guilty, Pay $206 Million, and Extend...

The Volkov Law Group on

Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty.  In 2019, Ericsson entered...more

Jones Day

FCPA 2022 Year in Review

Jones Day on

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

American Conference Institute (ACI)

[Event] Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2022 Developments and Predictions for 2023

WilmerHale on

While Foreign Corrupt Practices Act (FCPA) enforcement activity has not come close to returning to the heights seen a few years ago, 2022 reflected significant increases from the prior year in both the number of cases against...more

Oberheiden P.C.

Internal Audit for FCPA Compliance: A Detailed Guide

Oberheiden P.C. on

The Foreign Corrupt Practices Act (FCPA) (15 U.S.C. § 78dd-1 et seq.) is a federal anti-bribery law that makes it unlawful for certain people to pay foreign government officials in order to conduct business abroad. While it...more

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