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On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”).

As we previously discussed, on January 7, 2025, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction delaying the implementation of the Corporate Transparency Act’s (“CTA”) reporting requirements (Smith, et al. v. U.S. Department of the Treasury).

Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt Practices Act of 1977, as amended (the “FCPA”), and signaled a coming shift in how the statute will be enforced in the future.

On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry.

As we previously discussed, on December 5, 2024, the Department of Justice (“DOJ”), representing the Department of the Treasury, submitted a notice of appeal to the U.S. Court of Appeals for the Fifth Circuit, challenging a memorandum opinion and order issued by Judge Mazzant of the U.S. District Court for the Eastern District of Texas.

As we approach Inauguration Day on January 20, 2025, one question among anti-corruption practitioners is how the Trump administration will handle enforcement of the Foreign Corrupt Practices Act (“FCPA”).

As we previously discussed, on December 3, 2024, Judge Amos Mazzant of the U.S. District Court for the Eastern District of Texas issued a memorandum opinion and order granting a nationwide preliminary injunction against the Corporate Transparency Act (“CTA”), blocking implementation of the CTA in its entirety.

On Tuesday, December 3, 2024, Judge Amos Mazzant of the U.S. District Court for the Eastern District of Texas issued a memorandum opinion and order granting a nationwide preliminary injunction against the Corporate Transparency Act (“CTA”) and its implementing regulations.

While much attention is given to compliance with applicable laws, such as the U.S. Foreign Corrupt Practices Act of 1977, many companies working on projects sponsored by Multi-Lateral Development Banks overlook that they have subjected themselves to an entirely separate regime of anti-fraud and anti-corruption regulations with serious consequences for non-compliance.

In a long overdue move to fill a perceived gap in U.S. law, this year’s National Defense Authorization Act included a new law that will finally criminalize the solicitation of bribes by foreign officials.

It is one of the hardest questions a company can face: after discovering criminal conduct inside your company, do you self-report to the government or not?

Earlier this month, a federal judge vacated two convictions related to the Department of Justice’s (“DOJ”) investigation into corruption in international soccer, widely known as the “FIFA Case.”