With each new Administration comes a new approach or emphasis on certain enforcement priorities. The Trump Administration is marking its territory and doing so to underscore its priorities. In a recent speech, the Assistant Attorney General Matthew R. Galeotti for the Criminal Division announced DOJ’s new approach. To reinforce this new approach, DOJ issued a new memorandum, Focus, Fairness and Efficiency in the Fight Against...
For years, companies have dreaded DOJ’s potential appointment of a corporate monitorship as part of a criminal resolution. Companies have often complained about the experience, citing burdensome and sometimes unnecessary changes being required as part of a corporate monitorship. On the other hand, some companies who have completed a monitorship will acknowledge that the corporate monitor helped the company establish effective ethics and compliance program...
FCPA trends often are relatively easy to describe and often overblown as a marketing technique by the usual cast of paparazzi suspects. (Self-proclaimed prognosticators that often push incorrect themes to promote business, or those that restate profound grasps of the obvious). 2023 has been a strange year in a number of respects — socially, politically and even in the small universe of DOJ enforcement and...
