Subject to Inquiry

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THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Jason H. Cowley

Photo of Jason H. Cowley Jason Cowley, a former federal prosecutor, is the Chair of the firm’s Government Investigations and White Collar Litigation department and a member of the Securities Enforcement and Litigation practice group. He principally represents financial institutions (including investment funds), corporations, and executives in criminal investigations and trials, regulatory enforcement proceedings, and complex civil litigation. He also conducts internal investigations, undertakes transactional diligence, and advises on compliance matters. Jason has a particular expertise in matters involving securities and commodities fraud, cross-border enforcement issues, anti-money laundering issues, and criminal and civil asset forfeiture.

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Practical Tips for Companies Following President Trump’s Pause on FCPA Enforcement

By Caroline Schmidt Burton, Justin Givens, Alex J. Brackett, V. Kathleen Dougherty, Eric Snyder, Jason H. Cowley, John S. Moran, Roy Dixon III and Elizabeth Peters on Anti-Bribery and Corruption
Since the President signed the February 10, 2025 Executive Order (Order) pausing enforcement of the Foreign Corrupt Practices Act (FCPA) (Client Alert: President Trump issues Executive Order “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security”), companies with cross-border business operations have likely faced questions from both internal and external stakeholders… Continue Reading

Major Shift on Foreign Corrupt Practices Act: Trump Signs EO Pausing Enforcement

By Caroline Schmidt Burton, Justin Givens, Alex J. Brackett, Eric Snyder, John S. Moran, Jason H. Cowley, Patrick A. Wallace and Joie Johnston on Anti-Bribery and Corruption
Last night, in a move with wide-ranging implications for American companies doing business abroad, President Trump issued an executive order (Order) temporarily halting enforcement of the Foreign Corrupt Practices Act (FCPA).  The Order directs Attorney General (AG) Pam Bondi to review guidelines and policies governing FCPA investigations and enforcement actions in the next 180 days,… Continue Reading

The Foreign Extortion Prevention Act: Another Tool to Fight Foreign Corruption

By Katherine Richardson, Jason H. Cowley, Justin Givens and McGuireWoods LLP on Anti-Bribery and Corruption
In recent years, the Biden Administration has been vocal that combatting foreign public corruption is a key pillar of its national security efforts.[1]  Consistent with those policy goals, on December 22, 2023, Congress passed the Foreign Extortion Prevention Act (FEPA), a long-awaited complement to the Foreign Corrupt Practices Act (FCPA).  Where the FCPA targets those… Continue Reading

DOJ Announces Safe Harbor Policy for Mergers and Acquisitions

By Jason H. Cowley, Justin Givens, Edwin O. Childs, J. Brent Justus, Holden Brooks, Amy Manning and McGuireWoods LLP on Compliance, Enforcement and Prosecution Policy and Trends
In the U.S. Department of Justice’s continuing efforts to incentivize voluntary disclosure of corporate misconduct, Deputy Attorney General Lisa Monaco announced the Criminal Division’s latest corporate self-disclosure policy this week, aimed at mergers and acquisitions specifically (remarks Here).  Pursuant to DOJ’s new Mergers and Acquisitions Safe Harbor Policy (the “Policy”), acquiring companies that promptly and… Continue Reading

Departments of Justice, Commerce and Treasury Issue Tri-Seal Compliance Note on Voluntary Self-Disclosure of Potential Violations

By Alex J. Brackett, Patrick Rowan, Jason H. Cowley, Edwin O. Childs, Laura Colombell Marshall, Elissa Baur and McGuireWoods LLP on Sanctions, Trade Embargo, and Export Controls
On July 26, 2023, the U.S. Department of Justice’s National Security Division, U.S. Department of Commerce’s Bureau of Industry and Security, and U.S. Department of the Treasury’s Office of Foreign Assets Control issued a Tri-Seal Compliance Note (the Note) detailing updates to the three agencies’ voluntary self-disclosure policies applicable to violations of U.S. sanctions, export… Continue Reading

U.S. Department of Justice and Partners Increasing Enforcement of Sanctions and Export Controls

By Patrick Rowan, Alex J. Brackett, Jason H. Cowley, Edwin O. Childs, Laura Colombell Marshall and Elissa Baur on Sanctions, Trade Embargo, and Export Controls
It has been a little more than a year since Russia’s invasion of Ukraine, and the war continues to rage.  In an effort to deter the Russian government and weaken its military capabilities, the United States has imposed significant sanctions and export controls targeting Russia.  Recognizing that these sanctions and export control laws merit aggressive… Continue Reading

New Revelations in Ukraine Lead to Tightening Global Sanctions

By Alex J. Brackett, Edwin O. Childs, Patrick Rowan, Elissa Baur, Laura Colombell Marshall, Jason H. Cowley and Francesca Titus on Enforcement and Prosecution Policy and Trends, Sanctions, Trade Embargo, and Export Controls
RELATED UPDATE: FinCEN Alert Highlights Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites and Their Proxies (January 30, 2023) As the world watched in horror over the atrocities occurring in the war zones of Ukraine this week, global leaders re-doubled their efforts to bring increasing sanctions pressure to bear on Russian industry, the… Continue Reading

Western Companies Starting to Feel Impact of Russian Sanctions

By Alex J. Brackett, Edwin O. Childs, Patrick Rowan, Elissa Baur, Laura Colombell Marshall and Jason H. Cowley on Enforcement and Prosecution Policy and Trends, Financial Institution Regulation, Sanctions, Trade Embargo, and Export Controls
RELATED UPDATES: FinCEN Alert Highlights Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites and Their Proxies (January 30, 2023) New Revelations in Ukraine Lead to Tightening Global Sanctions (April 8, 2022) As we approach the thirty day mark since the United States, and other Western countries began imposing a series of rigorous sanctions… Continue Reading

DOJ Launches “Task Force KleptoCapture” in Response to Russian Invasion

By Laura Colombell Marshall, Edwin O. Childs, Alex J. Brackett, Patrick Rowan, Jason H. Cowley, Evan Tucker and Elissa Baur on Anti-Bribery and Corruption, Sanctions, Trade Embargo, and Export Controls
RELATED UPDATES: U.S. Department of Justice and Partners Increasing Enforcement of Sanctions and Export Controls (March 6, 2023) New Revelations in Ukraine Lead to Tightening Global Sanctions (April 8, 2022) Western Companies Starting to Feel Impact of Russian Sanctions (March 24, 2022) FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions… Continue Reading

U.S. and Allies Significantly Expand Sanctions and Related Restrictions on Russia and Belarus

By Alex J. Brackett, Edwin O. Childs, Patrick Rowan, Elissa Baur, Laura Colombell Marshall and Jason H. Cowley on Sanctions, Trade Embargo, and Export Controls
RELATED UPDATES: New Revelations in Ukraine Lead to Tightening Global Sanctions (April 8, 2022) Western Companies Starting to Feel Impact of Russian Sanctions (March 24, 2022) FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions including Use of Virtual Currency (March 16, 2022) DOJ Launches “Task Force KleptoCapture” in Response to… Continue Reading

Department of Justice Announces National Cryptocurrency Enforcement Team

By Jason H. Cowley, Edwin O. Childs, R. Andrew Austria and McGuireWoods LLP on Enforcement and Prosecution Policy and Trends, Financial Institution Regulation
On October 6, 2021, the U.S. Department of Justice (DOJ) announced its plans for increased scrutiny of the cryptocurrency market with the creation of a National Cryptocurrency Enforcement Team (NCET) to pursue criminal investigations and actions against cryptocurrency misuse. The NCET will focus on “crimes committed by virtual currency exchanges, mixing and tumbling services, and… Continue Reading

Sanctions and Export Compliance Strategies for Supply Chains

By Alex J. Brackett, Patrick Rowan and Jason H. Cowley on Compliance, Enforcement and Prosecution Policy and Trends, Sanctions, Trade Embargo, and Export Controls
The following is an excerpt from McGuireWoods’ recent contribution to the Global Investigations Review’s (GIR’s) The Guide to Sanctions – Second Edition published in July 2021. Authors Alex Brackett, Pat Rowan and Jason Cowley, each partners in the firm’s Government Investigations and White Collar Litigation department, penned a chapter on the Impacts of Sanctions and… Continue Reading

DOJ Accelerates Enforcement Efforts Against Cybercriminals Who Engage in Ransomware Attacks

By Jason H. Cowley, Patrick A. Wallace and McGuireWoods LLP on Enforcement and Prosecution Policy and Trends, Fraud, Deception and False Claims
On successive days last week, the Department of Justice (DOJ) unveiled enforcement actions against international cybercriminal organizations that utilized ransomware to infect computer systems and then extort payment, often in the form of cryptocurrency, from victims worldwide.  First, the Criminal Division’s Computer Crime and Intellectual Property Section and the U.S. Attorney’s Office for the Middle… Continue Reading

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