On September 5, 2025, the Securities and Exchange Commission (SEC) announced the creation of a new task force aimed at addressing cross-border fraud affecting U.S. investors. This move aligns with the Department of Justice’s (DOJ) Criminal Division’s May 2025 memorandum outlining its enforcement priorities and policies, as well as recent guidance
New DOJ FCPA guidance focused on vindicating US interests abroad
In February, President Trump signed Executive Order 14209, which paused enforcement of the Foreign Corrupt Practices Act (FCPA) pending new guidance to prosecutors on how the principal US foreign corruption statute would be enforced going forward. On June 9, 2025, Deputy Attorney General Todd Blanche issued the new DOJ guidelines for FCPA investigations
SCOTUS continues to curtail prosecutors: Gratuities not illegal under longstanding federal law
On June 26, 2024, the Supreme Court of the United States (SCOTUS) held in Snyder v. United States that 18 U.S.C. § 666 does not apply to gratuities — even those that raise eyebrows and ethical concerns. The federal statute prohibits public officials, including most state and local officials, from “corruptly” soliciting, accepting