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6.12.25
DOJ to Use FCPA as a Tool for Advancing White House Priorities and American Competitiveness
In February 2025, President Trump signed an executive order directing the U.S. Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) and to update its guidelines for enforcing the FCPA. The DOJ lifted the pause and released its new guidelines for FCPA enforcement. Below are the key takeaways for companies that conduct business internationally.
Alerts
4.21.25
California AG Warns Companies That FCPA Violations Are Still Enforceable Notwithstanding Federal Pause
On April 2, 2025, California Attorney General Rob Bonta issued a press release and legal advisory reminding businesses operating in California that violations of the Foreign Corrupt Practices Act (FCPA) are still actionable under California’s Unfair Competition Law (UCL), despite the Trump administration’s recent executive order implementing a pause on enforcement of the FCPA.
Alerts
2.13.25
Executive Order Temporarily Pauses DOJ's FCPA Enforcement and Orders a Review of Guidelines and Policies
On February 10, 2025, President Trump signed an executive order pausing enforcement of the Foreign Corrupt Practices Act (FCPA), a law that prohibits companies with a connection to the United States from bribing foreign government officials.
Alerts
3.30.23
"Sanctions Are the New FCPA": The Familiar Evolution of Sanctions Enforcement
Earlier this month, Deputy Attorney General for the U.S. Department of Justice (DOJ) Lisa Monaco reiterated that “sanctions are the new FCPA.” During the last year, the DOJ has begun pouring resources into sanctions enforcement, just as it did 20 years ago when it revitalized the Foreign Corrupt Practices Act (FCPA).
News Articles
11.16.21
Wilson Sonsini Named Among World’s Leading Firms for Investigations
On November 10, 2021, Wilson Sonsini Goodrich & Rosati was named to the 2021 edition of the GIR 100, an annual guide to the world’s leading cross-border investigations practices published by Global Investigations Review. Based on extensive research, the publication selected 100 law firms and 12 investigations consultancies from around the world that handle sophisticated cross-border government-led and internal investigations and related settlement negotiations or prosecutions of corporates and individuals.
The accompanying profile notes that the firm has “added to its investigations practice over the past year by recruiting big-name lawyers in New York and London,” and references several FCPA-related matters handled by the firm, including its representation of a group of shareholders in Africo Resources Limited who sued for restitution in an FCPA investigation against Och-Ziff, representation of several large cybersecurity companies in various FCPA investigations being conducted by the DOJ and SEC, representation of a computer scientist at a Chinese university who faced a charge of wire fraud conspiracy, and representation of witnesses in connection with an ongoing investigation into alleged corruption involving the Venezuelan state-owned oil and natural gas company PDVSA. The profile also highlights the practices of partners Caz Hashemi, Tarek Helou, Leo Cunningham, and Moe Fodeman, and mentions the recent hires of Jessica Lonergan and Mike Casey, as well as the return of Beth George.
For more information on the 2021 GIR 100 recognition, please click here.
The accompanying profile notes that the firm has “added to its investigations practice over the past year by recruiting big-name lawyers in New York and London,” and references several FCPA-related matters handled by the firm, including its representation of a group of shareholders in Africo Resources Limited who sued for restitution in an FCPA investigation against Och-Ziff, representation of several large cybersecurity companies in various FCPA investigations being conducted by the DOJ and SEC, representation of a computer scientist at a Chinese university who faced a charge of wire fraud conspiracy, and representation of witnesses in connection with an ongoing investigation into alleged corruption involving the Venezuelan state-owned oil and natural gas company PDVSA. The profile also highlights the practices of partners Caz Hashemi, Tarek Helou, Leo Cunningham, and Moe Fodeman, and mentions the recent hires of Jessica Lonergan and Mike Casey, as well as the return of Beth George.
For more information on the 2021 GIR 100 recognition, please click here.
News Articles
6.15.21
Tarek Helou Named to Global Investigation Review’s “Top FCPA Practitioners” List
On June 14, 2021, Global Investigations Review (GIR), a publication analyzing the law and practice of international investigations, recognized Wilson Sonsini Goodrich & Rosati partner Tarek Helou in its 2021 “Top FCPA Practitioners” list. A guide to the 30 leading lawyers and forensic advisers in the Foreign Corrupt Practices Act space, the list is based on extensive market research by GIR’s journalists.
Alerts
11.30.17
U.S. Department of Justice Adopts New FCPA Corporate Enforcement Policy to Enhance FCPA Pilot Program
When a company learns that an employee or third-party business partner may have bribed a foreign official, it is never an easy question as to whether the company should turn itself in to the U.S. government. On November 29, 2017, the Deputy Attorney General of the U.S. Department of Justice (DOJ), Rod J. Rosenstein, announced a new FCPA Corporate Enforcement Policy intended to make it easier for companies to answer that question with a "yes."1The Enforcement Policy, which governs DOJ criminal investigations, but not DOJ or U.S. Securities and Exchange Commission civil actions, has been incorporated into the U.S. Attorneys' Manual and posted on the DOJ's website.2