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…
In brief On June 26, 2024, in Snyder v. United States, the Supreme Court, in a 6-3 decision authored by Justice Kavanaugh, significantly limited the federal statute criminalizing gratuities in state and local jurisdictions. Snyder, a mayor, awarded a USD 1.3 million contract and received a USD 13,000 payment from the benefiting company. The Supreme Court ruled that the relevant statute, Title 18 section 666, applies only to bribes paid or promised before an official act,…
On March 18, 2024, the United States Securities and Exchange Commission (the “SEC”) announced that it settled charges against two investment advisers for making false and misleading statements about their purported use of artificial intelligence (AI). This SEC enforcement action marks the latest efforts by securities regulators to combat the adverse effects of “AI washing” and confirms that AI, and particularly “AI washing”, is at the forefront of securities regulators’ minds. What is “AI washing”?…