

The Liberty Mutual Declination: The Same, Only Different?
Earlier this month, the U.S. Department of Justice agreed not to prosecute Liberty Mutual Insurance Company despite evidence that its subsidiary paid nearly $1.5 million in bribes to officers of six state-owned banks in India. As part of the declination agreement, Liberty Mutual enhanced its compliance program, and agreed to disgorge profits.
Dave Lee
Aug 194 min read


FCPA Guidance Released
Since the February 2025 Executive Order pausing enforcement of the Foreign Corrupt Practices Act (FCPA), businesses, lawyers and the anti-corruption community awaited the outcome of the planned 180-day review. On June 9, we received some idea about what lies ahead, as Deputy Attorney General Todd Blanche released the memorandum Guidelines for Investigations and Enforcement of the Foreign Corrupt Practice Act.
Marc Schleifer
Jun 174 min read


FCPA Developments
In early February, the US Department of Justice announced it was temporarily pausing Foreign Corrupt Practices Act (FCPA) enforcement and adjusting future FCPA enforcement to prioritize Cartels and Transnational Criminal Organizations.
Dan Seltzer
Apr 1510 min read


The Hidden Costs of the FCPA Pause (Part 1): Corruption as a Business Practice & Erosion of Integrity
The Trump administration issued an executive order (EO) pausing enforcement of the Foreign Corrupt Practices Act (FCPA) to prioritize...
Michele Crymes
Mar 202 min read


Democracy in Danger: A Foreign Lobbying Law Rendered Toothless Once More
On February 5, 2025, Attorney General Pam Bondi scaled back enforcement of the Foreign Agents Registration Act (FARA), a law whose purpose..
Amaris Keys
Mar 63 min read


How Will the Foreign Aid Freeze Impact the Global Fight against Corruption?
On January 20, 2025, the Trump Administration issued an Executive Order on “Reevaluating and Realigning United States Foreign Aid” ....
Marc Schleifer
Feb 252 min read