Insights on Anti-Corruption & FCPA

On April 2, California Attorney General (AG) Rob Bonta issued an alert reminding businesses operating in California that it is illegal to violate the Foreign Corrupt Practices Act (FCPA).

With 2025 underway, the ArentFox Schiff White Collar team highlights the US Department of Justice’s (DOJ) new enforcement priorities and two cases pending before the US Supreme Court that could have sweeping implications for future white-collar fraud cases.

This article provides an analysis of recent updates to federal corporate compliance guidance on artificial intelligence and other new technologies.

This past September, the US Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs (ECCP).

In December 2023, US Congress passed a landmark anti-bribery law: the Foreign Extortion Prevention Act (FEPA). FEPA was designed to supplement the Foreign Corrupt Practices Act (FCPA) and expand liability to foreign government officials who solicit or accept bribes from US companies.

Global Investigations Review (GIR) has named ArentFox Schiff Partner Alexander S. Birkhold to its 2024 “40 Under 40” list.

US authorities announced that they reached an agreement with JPMorgan Chase & Co. (JPMorgan Chase) to settle criminal charges related to two distinct years-long market manipulation schemes involving hundreds of thousands of spoof orders on precious metals and US Treasury futures contracts. 

The Criminal Division of the US Department of Justice (DOJ) and Enforcement Division of the US Securities and Exchange Commission (SEC) recently published its second edition of A Resource Guide to the US Foreign Corrupt Practices Act (the “Updated Guide”), which was originally released in November 2

Earlier this week, the US Department of Justice published updated guidance on how it evaluates corporate compliance programs when conducting investigations, making charging decisions, and negotiating pleas or other agreements.

Partners Robert Capers and Hunter Carter were interviewed for a profile article by El Comercio during their recent business trip in Peru.

Arent Fox’s 2018 edition of the C-Suite at Risk, A Study of Individual Liability Under the FCPA examines every individual charged with a civil or criminal violation of the FCPA since 2005.

NEW YORK – The US Department of Justice remained busy in its first year of the Trump Administration, charging 20 individuals with violations under the US Foreign Corrupt Practices Act — the second highest year of individual prosecutions since 1977.

When companies create anti-bribery programs and provide training to staff, many understandably focus on bribery of foreign government officials.

Arent Fox Partner Peter Zeidenberg responded to President Donald Trump’s pardon of the chief of staff to former Vice President Dick Cheney during an interview on Yahoo News’ Skullduggery podcast.

Earlier this week, the United States Securities and Exchange Commission sent shockwaves through the financial-industry legal-and-compliance communities, announcing its largest-ever Dodd-Frank whistleblower awards, totaling $83 million.

There is no “adequate procedures” defense to bribery under the Foreign Corrupt Practices Act, but it has long been understood that maintaining a robust, risk-based compliance program can lead to reduced charges and penalties.

On July 28, 2015, Mead Johnson Nutrition Company, an Illinois-based pediatric food producer, settled FCPA charges brought by the SEC for over $12 million.

The US Supreme Court on Tuesday decided a closely watched False Claims Act (FCA) case, Kellogg Brown & Root Services, Inc. v. United States ex rel. Carter, with important implications for companies confronting FCA claims.

Alstom SA’s release today from World Bank sanctions ensures that the US Department of Justice (DOJ) will not impose an independent corporate monitor under its recent settlement with the company.

Foreign Corrupt Practices Act (FCPA) violations can lead to significant collateral consequences.

In a closely watched case, the US Court of Appeals for the Eleventh Circuit has concluded that officers and employees of a foreign government-owned company may be “foreign officials” for purposes of the anti-bribery prohibitions of the Foreign Corrupt Practices Act (FCPA).

Ralph Lauren Corporation has agreed to pay $1.6 million collectively to resolve allegations of misconduct under the Foreign Corrupt Practices Act for allegedly bribing government officials in Argentina.

Arent Fox White Collar Partner Michelle Shapiro (Arroyo) is leading an interactive half-day FCPA boot camp at ACI’s 21st New York Conference.

Government Enforcement & White Collar Partner Michelle Shapiro will speak at American Conference Institute’s 12th Advanced Forum on FCPA & Anti-Corruption for Arent Fox’s Life Sciences Industry on June 20 in New York.