Contrary to some expectations, the Trump Administration Department of Justice imposed record penalties under the U.S. Foreign Corrupt Practices Act from 2017 through 2020. But in each of those years, fewer and fewer new FCPA investigations were initiated. We expect the Biden Administration to continue the trend of increasing FCPA enforcement settlement values, while also increasing the pace of initiating new FCPA investigations. Anticorruption matters present some of the most severe threats to a company’s organizational integrity. Understanding the changing enforcement culture is an important component to addressing those threats.
Continue Reading The Next Four Years of FCPA Enforcement: What to Expect From the Biden Administration

CFIUS is expanding its reach. Where the Committee on Foreign Investment in the United States has generally scrutinized foreign acquisition of U.S. “critical infrastructure,” it has now signaled that it may look closely at any deal where the target collects or maintains sensitive personal information.
Continue Reading In-fo’ a CFIUS Review: The Expanding Power of CFIUS through Data Security Scrutiny

By: Reid Whitten and Cheryl Palmeri

On July 11, 2012, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued two general licenses lifting long-standing sanctions against Myanmar.  The licenses were issued in response to historic reforms that have taken place in the country over the past year, the details of which we reported in this blog in February and May of this year.
Continue Reading OFAC Authorizes the Exportation of Financial Services to and New Investment in Myanmar