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
Keith M. Rosen (US)
DOJ pits whistleblowers versus companies in a race to report criminal misconduct
On August 1, 2024, the US Department of Justice (DOJ) officially rolled out its Corporate Whistleblower Awards Pilot Program. The program is focused on financially incentivizing whistleblowers to report allegations of corporate crime.
Read our alert here.
Investigations Podcast Series – Episode 1: Early Stages of an Investigation
In the first episode of the Global Investigations Podcast Series, Andrew Reeves (Partner, Investigations, Enforcement and Compliance team, London) is joined by Ruth Cowley (Head of Disputes and Investigations, London), Keith Rosen (Head of Risk Advisory, US) and Sharon Oded (Head of Investigations, Amsterdam) to discuss the early stages of an investigation; best practice in…
New EU Anti-Corruption Framework: what does this mean for multinationals and their compliance programmes?
Summary
As part of a new anti-corruption package announced on 3 May 2023, the European Commission has proposed a new directive (Directive) which, if implemented, would require EU member states (Member States) to meet common standards in their anti-corruption legislation.
More detail on the EU’s anti-corruption package, including the proposed new…
US DOJ announces corporate criminal enforcement policy revisions
Following Deputy AG Lisa Monaco’s remarks at the White Collar Conference last year, the Department of Justice (DOJ) created a Corporate Crime Advisory Group to revise DOJ’s Corporate Criminal Enforcement Policies. On September 15, 2022, Monaco announced the group’s first major round of revisions. The revisions reiterate a focus on individual accountability, voluntary…
U.S. Strategy on Countering Corruption: Key points for international companies
On 6 December 2021, the Biden Administration released its strategy on countering corruption (the Strategy) along with an accompanying fact sheet, building on President Biden’s earlier announcement that he viewed the fight against corruption as one of the core U.S. national security priorities. The five-point strategy places particular focus on a coordinated international…
US Justice Department is “surging” resources to corporate enforcement
High-level officials at the Justice Department are warning that the DOJ is “surging” resources in a new effort to combat corporate crime.…
New US DOJ guidance on corporate compliance programs emphasizes dynamic program design and implementation
During the summer, the United States Justice Department announced the latest set of updates to its “Evaluation of Corporate Compliance Programs” policy. The policy, which was first released in 2017 and revised last year, provides companies with detailed guidance on how the Department will review the adequacy and effectiveness of compliance programs when making charging…
What is the STOCK Act?
The STOCK Act clarifies that members of Congress and other congressional employees do, in fact, have a duty of trust and confidence to the Congress, the United States Government, and US citizens.…