Sky Blog
On May 12, 2025, the Head of the Department of Justice’s (“DOJ”) Criminal Division, Matthew R. Galeotti, announced significant changes to the Criminal Division’s corporate and white-collar enforcement policies and priorities.[1] Speaking at the Securities Industry and Financial Markets …
President Trump signed on February 10 an executive order (the “Executive Order”)[1] directing the U.S. Attorney General over the next 180 days to (i) review the guidelines and policies governing investigations and enforcement actions under the Foreign Corrupt Practices …
The U.S. Department of Justice (DOJ or Department) has announced a significant shift in enforcement priorities concerning digitalassets. On April 7, 2025, Deputy Attorney General Todd Blanche issued a memorandum (Memorandum) announcing that the Department is not a “digital assets …
Shifting U.S. enforcement priorities may soon create a crisis in international anti-corruption efforts. For decades, the United States spearheaded those efforts through prosecutions under the Foreign Corrupt Practices Act (FCPA). On February 10, however, President Donald Trump issued an Executive …
On February 12, President Trump issued an Executive Order and Fact Sheet ordering, among other things, that the U.S. Attorney General cease initiation of any new FCPA investigations or enforcement actions for 180 days. As CEOs and boards of …
On February 10, 2025, President Donald Trump signed an executive order directing the U.S. attorney general, Pam Bondi, to pause Foreign Corrupt Practices Act (FCPA) actions for 180 days until she issues revised FCPA enforcement guidance to “prioritize American interests, …
In our most recent memorandum, we predicted that President Trump’s second administration would likely entail a significant overhaul of DOJ’s agenda and enforcement priorities. Although we are less than a month into the new Trump Administration, we have already seen …
Each month, we publish a roundup of the most important SEC enforcement developments. This month included the SEC’s fiscal year end and a large number of enforcement actions of note, and we examine:
Why did two federal courts refuse to throw out Foreign Corrupt Practices Act (FCPA) charges against two different commodities traders? What revisions did Congress make to the Foreign Extortion Prevention Act (FEPA)? How has China increased its anti-corruption scrutiny of …
The Biden-Harris administration has been keenly focused on mitigating climate risk, which has resulted in several executive and legislative actions promoting the use of electric vehicles (EVs), with a stated goal of having 50% of all new vehicles …
On January 10, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced parallel resolutions with SAP, a German software company, to resolve investigations into violations of the Foreign Corrupt Practices Act (FCPA). According to the resolutions, …
On December 14, 2023, Congress passed the Foreign Extortion Prevention Act (“FEPA”) as a component of the annual National Defense Authorization Act to criminally prosecute foreign officials who seek or receive bribes from U.S. persons or businesses. President Biden is …
The Securities and Exchange Commission announced that it filed 784 total enforcement actions in fiscal year 2023, a 3 percent increase over fiscal year 2022, including 501 original, or “stand-alone,” enforcement actions, an 8 percent increase over the prior fiscal …
Department of Justice (DOJ) prosecutors are empowered to resolve serious corporate criminal allegations through deferred prosecution agreements (DPA). In a new paper, I argue that DPAs should not be permitted when corporate misconduct causes people to lose their lives.
To …
Recently, the whole of the U.S. government has showcased its commitment to addressing the national security implications of certain corporate activities. On September 11, 2023, the U.S. Department of Justice (DOJ) tapped its first National Security Corporate Enforcement Chief. The …
Over the past 25 years, there has been a significant evolution in businesses’ obligations both to combat corruption and to respect human rights. The late-1990s saw the emergence of a global anti-corruption norm, which resulted in the 2003 United Nations …
On July 26, 2023, the U.S. Department of Justice’s National Security Division (“NSD”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Tri-Seal …
The Securities and Exchange Commission today [November 15] announced that it filed 760 total enforcement actions in fiscal year 2022, a 9 percent increase over the prior year. These included 462 new, or “stand alone,” enforcement actions, a 6.5 percent …
On October 18, 2022, Deputy Attorney General (“DAG”) Lisa O. Monaco announced that Lafarge SA (“Lafarge”), a multi-national building materials manufacturer headquartered in Paris, France, and its Syrian subsidiary Lafarge Cement Syria (“LCS”) had pleaded guilty in the Eastern District …
At a recent New York City Bar Association event, Deputy Attorney General Lisa Monaco emphasized the Department of Justice’s focus on sanctions evasion and export control violations as key to its work to combat corporate crime.
At …