As highlighted in this prior post, approximately 5 years ago, Japan-based Toyota Motor Company disclosed as follows.
“In April 2020, Toyota reported possible anti-bribery violations related to a Thai subsidiary to the SEC and the U.S. Department of Justice (“DOJ”), and is cooperating with their investigations. The investigations could result in the imposition of
Rewind
By Mike Koehler
A meaningful amount of “stuff” written about the Foreign Corrupt Practices Act – including by “major” media sources or so-called “experts” – completely lacks context.
With context lacking, many things may seem new (and thus controversial) when in reality the development is hardly new.
With the DOJ’s recent release of a policy memo titled “Guidelines…
Many Of The Topics Discussed In The FCPA Guidelines Are Not New
By Mike Koehler
On June 9th, DOJ Deputy Attorney General Todd Blanche issued this memo to the head of the DOJ Criminal Division titled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act.”
At first blush, it may seem like there are many new topics in the Guidelines.
What is perhaps new is that these topics…
The 118 Day “Pause” That Was
By Mike Koehler
When President Trump issued an Executive Order on February 10th titled ““Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security,” some people seemingly had a “come apart.”
Those subject to the FCPA were all of a sudden going to go on a bribery binge.
American global competitiveness and national security were…
DOJ Criminal Division Head Galeotti On …
By Mike Koehler
Yesterday, DOJ Criminal Division head Matthew Galeotti gave this speech in which talked about the DOJ’s recently released “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act.” (See here for the prior post) as well as the DOJ “White Collar Enforcement Plan” released last month (see here for the prior post).
Galeotti began:…
DOJ Releases Guidelines For Investigations And Enforcement Of The FCPA
By Mike Koehler
Yesterday, DOJ Deputy Attorney General Todd Blanche issued this memo to the head of the DOJ Criminal Division titled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act.”
The memo begins:
“On February 10, 2025, President Trump signed Executive Order 14209, titled Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and…
Since February 10th
By Mike Koehler
On February 10th, President Trump signed an Executive Order Titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.”
Set forth below are FCPA (and related) developments since February 10th.
Linking all of these developments directly and solely to the Executive Order would be foolish as pre-February 10th many of these…
Checking In On Monkey Business
By Mike Koehler
In mid-2023 some unique instances of FCPA scrutiny arose.
As highlighted in this prior post, Inotiv Inc. (an Indiana based “contract research organization (“CRO”) dedicated to providing nonclinical and analytical drug discovery and development services to the pharmaceutical and medical device industries and selling a range of research-quality animals and diets to the same…
In A Pending FCPA Matter, DOJ Files Superseding Information
By Mike Koehler
In late 2023, the DOJ announced the unsealing of an indictment criminally charging: Carl Alan Zaglin (the owner of a Georgia-based manufacturer of law enforcement uniforms and accessories); Francisco Roberto Cosenza Centeno (former Executive Director of the Comité Técnico del Fideicomiso para la Administración del Fondo de Protección y Seguridad Poblacional (TASA) a Honduran governmental entity that…
National Security And The FCPA
By Mike Koehler
The February 10th Executive Order issued by President Trump titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security” mentions national security four times including in the title.
Some people seemingly had a “come apart” regarding this, however national security and FCPA issues have always been intertwined.
In fact, during the…