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Category Archives: Anti-Bribery and Corruption

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Anti-Bribery and Corruption

Europe Steps Up as U.S. Pauses FCPA Enforcement: What Companies Need to Know About the New International Anti-Corruption Taskforce

In a significant move signaling Europe’s growing autonomy in global anti-corruption enforcement, prosecutors from the United Kingdom, France, and Switzerland have formed a new cross-border alliance: the International Anti-Corruption Prosecutorial Taskforce. Announced on March 20, 2025 by the U.K.’s Serious Fraud Office (SFO), the taskforce is designed to deepen cooperation among these three countries on… Continue Reading
Anti-Bribery and Corruption

Texas Court Stays Nationwide Injunction Staying the CTA, Deadline to Report Beneficial Ownership Information is March 21, 2025

In our last update, we reported that despite the Supreme Court staying the nationwide injunction against FinCEN’s enforcement of the CTA in one Texas case, a nationwide stay of the Reporting Rule granted by a federal judge in the Eastern District in Smith v. United States Department of Treasury (6:24-cv-00336) remained in effect. … Continue Reading
Anti-Bribery and Corruption

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

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
Anti-Bribery and Corruption

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

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
Anti-Bribery and Corruption

DOJ Seeks Supreme Court Review of CTA Injunction

Another flurry of court activity has further muddied the Corporate Transparency Act (CTA) waters, leaving additional uncertainty about its enforceability.  You may recall that on December 26, 2024, the Fifth Circuit vacated its own order granting the Government’s motion to stay the district court’s preliminary injunction, leaving FinCEN unable to enforce the CTA and lifting any filing… Continue Reading
Anti-Bribery and Corruption

Corporate Transparency Act Reporting Obligations: On Hold Until At Least Late March 2025

A flurry of activity in the Fifth Circuit this holiday season left clients asking the same questions about the Corporate Transparency Act (CTA): “Do we report Beneficial Ownership Information?”  “If so, when is the deadline?”  “Will this Act survive judicial review?” You may recall that on December 26, 2024, the Fifth Circuit vacated the “part… Continue Reading
Anti-Bribery and Corruption

The Foreign Extortion Prevention Act: Another Tool to Fight Foreign 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
Anti-Bribery and Corruption

Ericsson Pleads Guilty, Agrees to Pay $206M in Fines, Following Alleged Violation of FCPA Deferred Prosecution Agreement

Last week, the U.S. Department of Justice (DOJ) announced that Sweden-based multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson) will plead guilty to breaching the Foreign Corrupt Practices Act (FCPA) and has agreed to pay over $206 million in related penalties following its alleged breach of a 2019 Deferred Prosecution Agreement (DPA) with the Department.… Continue Reading
Anti-Bribery and Corruption, Sanctions, Trade Embargo, and Export Controls

Cross-Border Enforcement and Trends — 2022 Year in Review

Key developments in U.S. cross-border enforcement were driven by the year’s most newsworthy developments, from Russia’s invasion of Ukraine and the battery of sanctions that swiftly followed, to the collapse of the cryptocurrency market. For details, download this inaugural review, which focuses on anti-money laundering, as this issue continued its rise up the enforcement and… Continue Reading
Anti-Bribery and Corruption

Brazilian Airline to Pay Millions in Coordinated Foreign Bribery Resolution

On September 15, 2022, GOL Linhas Aéreas Inteligentes S.A. (GOL), Brazil’s second largest domestic airline, resolved long-running parallel investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). The São Paulo-based company, whose shares are traded on the New York Stock Exchange, consented to a cease-and-desist order with the SEC… Continue Reading
Anti-Bribery and Corruption

DOJ and SEC Kick Off the Second Quarter with Major FCPA Settlement with International Waste Management Company

On April 20, 2022, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) separately announced that Stericycle Inc. (Stericycle), an international waste management company headquartered in Lake Forest, Illinois, has agreed to pay more than $84 million to resolve parallel investigations by authorities in the United States and Brazil. The investigation is… Continue Reading
Anti-Bribery and Corruption, Sanctions, Trade Embargo, and Export Controls

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

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
Anti-Bribery and Corruption, Sanctions, Trade Embargo, and Export Controls, Securities and Commodities

The Perils of Global Expansion: World’s Largest Ad Agency Sanctioned $19 Million for FCPA Violations, Insufficient Controls

Global expansion without adequate controls is asking for trouble. That’s the lesson of a $19 million settlement between WPP, the world’s largest advertising agency, and the U.S. Securities and Exchange Commission (SEC) to resolve alleged violations of the Foreign Corrupt Practices Act (FCPA). According to an SEC order memorializing the settlement, WPP’s trouble began when… Continue Reading
Anti-Bribery and Corruption

Unexplained Wealth Orders

Background For some time there has been a perception that the UK is a safe refuge for corrupt individuals seeking to conceal their unlawfully acquired assets. This has particularly been the case with regard to persons from countries outside the UK. The Government has sought to address this by amending the Proceeds of Crime Act… Continue Reading
Anti-Bribery and Corruption

Expansion of FCPA “Pilot Program” is Good for Companies, but Heed the Fine Print

Deputy Attorney General Rod Rosenstein’s Nov. 29 announcement that the Department of Justice FCPA “Pilot Program” will be permanently expanded is good news for companies that repeatedly faced the dilemma of whether or not to investigate and disclose FCPA issues discovered internally. However, companies should be careful to read the fine print of the policy… Continue Reading
Anti-Bribery and Corruption, Enforcement and Prosecution Policy and Trends

SEC Expected to Expedite FCPA Investigations in Light of Kokesh

On November 9, 2017, Steven R. Peikin, Co-Director of the SEC’s Division of Enforcement, delivered a keynote speech at a conference commemorating the 40th anniversary of the enactment of the Foreign Corrupt Practices Act (“FCPA”) in which he reflected on “the past, present, and future” of the SEC’s enforcement of the FCPA. After confirming the… Continue Reading
Anti-Bribery and Corruption, Enforcement and Prosecution Policy and Trends

Last Four Months of DOJ’s FCPA Pilot Program Could Provide Important Signals

Last April, the Criminal Division of the U.S. Department of Justice launched a one-year pilot program in the Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit.  The pilot program, self-described as “building” on the Yates memorandum, provides structured incentives for companies to self-disclose, cooperate, and remediate with respect to FCPA violations.  The remaining four months… Continue Reading
Anti-Bribery and Corruption, Anti-Money Laundering, Compliance, Enforcement and Prosecution Policy and Trends

UK set to shake up Corruption and Money Laundering Enforcement

The UK Government introduced the Criminal Finances Bill to Parliament today (13 October 2016), which will now start its passage through the parliamentary approval process before becoming law. The Government hopes that the Bill “will significantly improve the government’s ability to tackle money laundering and corruption, recover the proceeds of crime, and counter terrorist financing”, and… Continue Reading
Anti-Bribery and Corruption, Compliance, Energy Enforcement

A Compliance Plan for the Extractive Industries Payment Disclosure Rule

In the prior post we described the SEC’s new Rule 13q-1 that took effect on Monday (September 26). In this post, we discuss steps covered companies should take to comply with the rule. To review: Rule 13q-1 requires issuers involved in the commercial development of oil, natural gas and minerals to disclose payments they, their… Continue Reading

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