In brief On February 10, 2025, President Donald Trump signed an Executive Order (“Order”) directing a 6-month moratorium on the enforcement of the Foreign Corrupt Practices Act (FCPA), while the Attorney General revises Department of Justice (DOJ) policies and guidelines governing FCPA enforcement. The Order instructs that these changes be made in the interest of promoting US companies’ ability to compete in foreign markets. While the Order introduces uncertainty for the future of FCPA enforcement,…
An analysis of Attorney General Bondi’s memorandum on the Foreign Corrupt Practices Act (FCPA) In brief A recent memorandum from Attorney General Pam Bondi signals a potential shift in the Department of Justice’s (DOJ) FCPA enforcement priorities. According to the memorandum, FCPA enforcement should prioritize foreign bribery linked to Cartels and Transnational Criminal Organizations (TCOs), potentially altering the landscape of white-collar corporate enforcement. While traditional FCPA cases will likely continue, the new directive grants local…
DOJ Extends Leniency Incentives to Corporate Wrongdoers Who Disclose Criminal Misconduct In brief On April 15, 2024, the DOJ launched the Individual Voluntary Self-Disclosures (VSD) Program, extending incentives for individual wrongdoers to self-report criminal activities. This follows similar initiatives in the SDNY and NDCA. Traditionally, the DOJ incentivized corporate self-disclosure of wrongdoing. The new program aims to encourage individuals to disclose their misconduct and cooperate fully in exchange for non-prosecution agreements, potentially heightening the pressure…