DOJ Proclaims First FCPA Enforcement Exercise After Months-Lengthy Pause

by Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, and Christopher Cestaro

Left to Proper: Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, and Christopher Cestaro (pictures courtesy of WilmerHale)

Over the previous week, the U.S. Division of Justice (“DOJ”) unsealed its first Overseas Corrupt Practices Act (“FCPA”) enforcement motion and issued its first declination for the reason that pause in FCPA enforcement mandated by President Donald Trump’s February 10, 2025 Government Order (“February Government Order”)[1] and the next issuance of up to date FCPA enforcement pointers, the Tips for Investigations and Enforcement of the Overseas Corrupt Practices Act (FCPA) (“June Tips”).[2]  

As we famous in our current consumer alert,[3] the June Tips directed FCPA investigations and enforcement actions to deal with a non-exhaustive checklist of things that align with the administration’s acknowledged priorities: eliminating cartels and transnational prison organizations (TCOs); safeguarding U.S. enterprise competitiveness; advancing U.S. nationwide safety; and prioritizing investigations of great misconduct versus routine enterprise practices in different nations. The conduct concerned within the indictment and within the declination doesn’t seem to squarely match into the 4 named components, suggesting that the FCPA Unit won’t be strictly confined by these components in follow.

The post-pause declination additionally seems to observe the necessities of the DOJ’s revised Company Enforcement and Voluntary Self-Disclosure Coverage (“CEP”),[4] underneath which firms will obtain a declination—not only a presumption of a declination—for voluntarily self-reporting, cooperating and remediating violations of the FCPA (though it isn’t clear that the matter would have been resolved otherwise underneath the prior model of the CEP).

On August 11, 2025, the DOJ unsealed its first FCPA indictment for the reason that pause in FCPA enforcement mandated by the February Government Order.[5] The indictment describes conduct largely much like issues that have been pursued by the FCPA Unit previous to the pause, although features of the case align to a point with the coverage objectives expressed within the June Tips.

The indictment costs two Mexican businessmen, Ramon Alexandro Rovirosa Martinez and Mario Alberto Avila Lizarraga, for his or her alleged involvement in a bribery scheme to retain and acquire greater than $2.5 million in contracts with the state-owned Mexican oil firm Petróleos Mexicanos (“PEMEX”) and its exploration and manufacturing subsidiary, PEMEX Exploración y Producción (“PEP”).[6] Each of the people charged are Mexican residents and lawful everlasting residents of the US who reside in Texas. 

A separate DOJ movement associated to Mr. Rovirosa’s conditional launch notes that he has “ties to Mexican cartel members and that he was beforehand concerned in violent conduct in Mexico,” a declare that doesn’t seem within the indictment itself and doesn’t seem straight related to the bribery allegations.[7]

The indictment alleges that between roughly June 2019 and October 2021, Mr. Rovirosa and Mr. Avila, with the assistance of at the very least three unindicted co-conspirators, orchestrated a number of schemes to bribe officers of PEMEX and PEP to safe profitable contracts for Mr. Rovirosa’s companies.[8] Mr. Rovirosa owned, managed or was in any other case related to six privately owned Mexican vitality firms.[9] Mr. Avila labored for the advantage of Mr. Rovirosa and his firms.[10] 

In accordance with the indictment, on the course of Mr. Rovirosa, Mr. Avila allegedly paid roughly $150,000 price of bribes within the type of money funds and luxurious objects—akin to a Louis Vuitton purse, Hublot watches and a $26,000 treadmill—to PEMEX and PEP officers with the objective of acquiring and retaining contracts for Mr. Rovirosa’s firms.[11] On account of the bribe funds, PEMEX and PEP officers allegedly: (1) directed different PEMEX and PEP staff to favorably resolve an audit associated to a few of Mr. Rovirosa’s firms in order that these firms might get hold of further enterprise with PEMEX and PEP; (2) ensured that sure of Mr. Rovirosa’s firms have been awarded a roads and platforms work contract with PEMEX and PEP; and (3) intervened within the bidding course of to award a contract with PEMEX and PEP to different Rovirosa firms associated to the mechanical integrity of floor installations.[12] Consequently, the indictment asserts that Mr. Rovirosa’s firms have been awarded roughly $2.5 million price of PEMEX and PEP contracts.[13]

The indictment asserts jurisdiction over each defendants underneath the anti-bribery provisions of the FCPA on the premise that they’re “home issues,” as each defendants reside in Texas and are lawful everlasting residents of the US. A good portion of the proof described within the indictment is comprised of WhatsApp messages between Mr. Avila and PEMEX or PEP officers, a lot of which Mr. Avila allegedly despatched or acquired on the course of Mr. Rovirosa whereas Mr. Avila was throughout the Southern District of Texas. Within the cited messages, Mr. Avila and the PEMEX and PEP officers mentioned, amongst different issues, securing a positive audit decision for Mr. Rovirosa’s firms, awarding the roads and platforms contract to sure of Mr. Rovirosa’s firms, and awarding the mechanical integrity contract to different of these firms—in addition to the associated funds from Mr. Rovirosa and Mr. Avila.[14]  

Final week, the DOJ additionally issued its first FCPA declination pursuant to the CEP for the reason that pause in enforcement, declining to prosecute a U.S.-based firm for doable FCPA violations arising out of its brokers’ alleged actions in India.[15] In accordance with the letter, staff of the corporate’s subsidiary licensed improper funds to officers at state-owned banks in India to ensure that the banks to refer their clients to the subsidiary’s merchandise. The DOJ issued the declination on the premise of the corporate’s well timed and voluntary self-disclosure (which occurred in 2024, throughout the prior administration); its cooperation with the DOJ; the character and seriousness of the offense; the corporate’s remediation efforts; the absence of aggravating circumstances; and the corporate’s settlement to disgorge roughly $4.7 million in earnings from the conduct. The declination letter describes conduct very a lot within the heartland of circumstances that might have acquired a declination previous to the June Tips.

As we famous in our consumer alert relating to the DOJ’s June Tips,[16] the DOJ seems poised to proceed some FCPA enforcement exercise underneath the present administration. In gentle of the primary indictment and declination following the FCPA enforcement pause, firms ought to think about:

• Given the DOJ’s acknowledged prioritization of cartels and TCOs, the current indictment could also be a sign that conduct in Mexico and elsewhere in Latin America will obtain higher scrutiny by U.S. regulation enforcement authorities. Firms ought to be certain that acceptable compliance assets are dedicated to their actions within the area.
• The comparatively small whole worth of the alleged bribe funds within the indictment—$150,000—is a reminder that U.S. authorities aren’t limiting their consideration to “blockbuster” issues however fairly will nonetheless pursue run-of-the-mill circumstances related to people who have been pursued previous to the pause.  
• Whereas the June Tips famous that FCPA enforcement shouldn’t penalize “routine enterprise practices in different nations,”[17] the indictment referring to the availability of a Louis Vuitton purse, Hublot watches and a $26,000 treadmill means that “routine enterprise practices” don’t embrace luxurious items, and U.S. enforcers will proceed to pursue such circumstances the place items are of a price that arguably might affect the habits of the recipient.
• The DOJ’s reliance on Mr. Avila’s WhatsApp messages as the first supply of proof within the indictment ought to function a reminder of the significance positioned on “off channel” communications sources by the DOJ and that firms want to take care of clear insurance policies on the usage of messaging purposes for enterprise functions and retain data of acceptable communications.[18]
• Curiously, there is no such thing as a specific indication within the indictment that the related firms have been competing with U.S. firms or that U.S. firms have been harmed in any approach, regardless of the June Tips’ emphasis on limiting undue burdens on American firms that function overseas.[19] And, as famous above, any alleged connections to cartels appear unrelated to the conduct at concern.
• Equally, the declination bolsters the conclusion that the DOJ will proceed to pursue enforcement actions for conduct that falls outdoors the components outlined within the June Tips.
• Lastly, the declination demonstrates that the DOJ will proceed to concern declinations underneath the CEP for firms that self-disclose potential FCPA violations, totally cooperate, remediate and disgorge earnings referring to the improper conduct.

Future enforcement actions will little doubt present further perception into the DOJ’s concerns for opening, investigating and resolving FCPA circumstances in addition to how such concerns might or might not relate to the components outlined within the June Tips.[20]

[1] Exec. Order, Pausing Overseas Corrupt Practices Act Enforcement to Additional American Financial and Nationwide Safety (February 10, 2025), https://www.whitehouse.gov/presidential-actions/2025/02/pausingforeign-corrupt-practices-act-enforcement-to-further-american-economic-and-national-security/. See WilmerHale, President Trump and Lawyer Basic Bondi Announce Vital Shift in FCPA and Different Company Enforcement Priorities (February 11, 2025), https://www.wilmerhale.com/en/insights/client-alerts/20250211-president-trump-and-attorney-general-bondi-announce-significant-shift-in-fcpa-and-other-corporate-enforcement-priorities.

[2] Memorandum from the Deputy Lawyer Basic, Tips for Investigations and Enforcement of the Overseas Corrupt Practices Act (FCPA) (June 9, 2025), https://www.justice.gov/dag/media/1403031/dl.

[3] WilmerHale, Division of Justice Proclaims FCPA Tips (June 10, 2025), https://www.wilmerhale.com/en/insights/client-alerts/20250610-department-of-justice-announces-fcpa-guidelines.

[4] DOJ, Felony Division Company Enforcement and Voluntary Self-Disclosure Coverage, JUSTICE MANUAL § 9-47.120 (Up to date Could 12, 2025), https://www.justice.gov/prison/media/1400031/dl?inline. 

[5] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1.

[6] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1.

[7] Mot. To Impose Sure Situations of Launch, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 11, 2025), ECF No. 11. See additionally Indictment, United States v. Rovirosa; Press Launch, U.S. Dep’t of Justice, Two Mexican Nationals Charged for Bribing State-Owned Power Officers (August 11, 2025), https://www.justice.gov/opa/pr/two-mexican-nationals-charged-bribing-state-owned-energy-officials.  

[8] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶ 12.

[9] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶¶ 4-5.

[10] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶¶ 4-5.

[11] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶¶ 12, 15-16.

[12] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶ 13.

[13] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶ 14.

[14] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶¶ 18-21, 23-26, 29, 31-35, 40-51, 54-58.

[15] U.S. Division of Justice Letter (Aug. 7, 2025), https://www.justice.gov/prison/media/1410761/dl?inline.

[16] WilmerHale, Division of Justice Introduced FCPA Tips (June 10, 2025), https://www.wilmerhale.com/en/insights/client-alerts/20250610-department-of-justice-announces-fcpa-guidelines.

[17] Memorandum from the Deputy Lawyer Basic, Tips for Investigations and Enforcement of the Overseas Corrupt Practices Act (FCPA) (June 9, 2025), https://www.justice.gov/dag/media/1403031/dl.

[18] DOJ, Felony Division Company Enforcement and Voluntary Self-Disclosure Coverage, JUSTICE MANUAL § 9-47.120 (Up to date Could 12, 2025), https://www.justice.gov/prison/media/1400031/dl?inline.  

[19] Memorandum from the Deputy Lawyer Basic, Tips for Investigations and Enforcement of the Overseas Corrupt Practices Act (FCPA) (June 9, 2025), https://www.justice.gov/dag/media/1403031/dl.

[20] Along with the contributors listed under Emily L. Stark, Masha Goncharova and Walker Schulte Schneider additionally offered priceless help within the overview and drafting course of. 

Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, and Christopher Cestaro are Companions at WilmerHale. This text first appeared on the agency’s weblog.

The views, opinions and positions expressed inside all posts are these of the creator(s) alone and don’t characterize these of the Program on Company Compliance and Enforcement (PCCE) or of the New York College College of Legislation. PCCE makes no representations as to the accuracy, completeness and validity or any statements made on this web site and won’t be liable any errors, omissions or representations. The copyright of this content material belongs to the creator(s) and any legal responsibility with reference to infringement of mental property rights stays with the creator(s).

by Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, and Christopher Cestaro

Left to Proper: Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, and Christopher Cestaro (pictures courtesy of WilmerHale)

Over the previous week, the U.S. Division of Justice (“DOJ”) unsealed its first Overseas Corrupt Practices Act (“FCPA”) enforcement motion and issued its first declination for the reason that pause in FCPA enforcement mandated by President Donald Trump’s February 10, 2025 Government Order (“February Government Order”)[1] and the next issuance of up to date FCPA enforcement pointers, the Tips for Investigations and Enforcement of the Overseas Corrupt Practices Act (FCPA) (“June Tips”).[2]  

As we famous in our current consumer alert,[3] the June Tips directed FCPA investigations and enforcement actions to deal with a non-exhaustive checklist of things that align with the administration’s acknowledged priorities: eliminating cartels and transnational prison organizations (TCOs); safeguarding U.S. enterprise competitiveness; advancing U.S. nationwide safety; and prioritizing investigations of great misconduct versus routine enterprise practices in different nations. The conduct concerned within the indictment and within the declination doesn’t seem to squarely match into the 4 named components, suggesting that the FCPA Unit won’t be strictly confined by these components in follow.

The post-pause declination additionally seems to observe the necessities of the DOJ’s revised Company Enforcement and Voluntary Self-Disclosure Coverage (“CEP”),[4] underneath which firms will obtain a declination—not only a presumption of a declination—for voluntarily self-reporting, cooperating and remediating violations of the FCPA (though it isn’t clear that the matter would have been resolved otherwise underneath the prior model of the CEP).

On August 11, 2025, the DOJ unsealed its first FCPA indictment for the reason that pause in FCPA enforcement mandated by the February Government Order.[5] The indictment describes conduct largely much like issues that have been pursued by the FCPA Unit previous to the pause, although features of the case align to a point with the coverage objectives expressed within the June Tips.

The indictment costs two Mexican businessmen, Ramon Alexandro Rovirosa Martinez and Mario Alberto Avila Lizarraga, for his or her alleged involvement in a bribery scheme to retain and acquire greater than $2.5 million in contracts with the state-owned Mexican oil firm Petróleos Mexicanos (“PEMEX”) and its exploration and manufacturing subsidiary, PEMEX Exploración y Producción (“PEP”).[6] Each of the people charged are Mexican residents and lawful everlasting residents of the US who reside in Texas. 

A separate DOJ movement associated to Mr. Rovirosa’s conditional launch notes that he has “ties to Mexican cartel members and that he was beforehand concerned in violent conduct in Mexico,” a declare that doesn’t seem within the indictment itself and doesn’t seem straight related to the bribery allegations.[7]

The indictment alleges that between roughly June 2019 and October 2021, Mr. Rovirosa and Mr. Avila, with the assistance of at the very least three unindicted co-conspirators, orchestrated a number of schemes to bribe officers of PEMEX and PEP to safe profitable contracts for Mr. Rovirosa’s companies.[8] Mr. Rovirosa owned, managed or was in any other case related to six privately owned Mexican vitality firms.[9] Mr. Avila labored for the advantage of Mr. Rovirosa and his firms.[10] 

In accordance with the indictment, on the course of Mr. Rovirosa, Mr. Avila allegedly paid roughly $150,000 price of bribes within the type of money funds and luxurious objects—akin to a Louis Vuitton purse, Hublot watches and a $26,000 treadmill—to PEMEX and PEP officers with the objective of acquiring and retaining contracts for Mr. Rovirosa’s firms.[11] On account of the bribe funds, PEMEX and PEP officers allegedly: (1) directed different PEMEX and PEP staff to favorably resolve an audit associated to a few of Mr. Rovirosa’s firms in order that these firms might get hold of further enterprise with PEMEX and PEP; (2) ensured that sure of Mr. Rovirosa’s firms have been awarded a roads and platforms work contract with PEMEX and PEP; and (3) intervened within the bidding course of to award a contract with PEMEX and PEP to different Rovirosa firms associated to the mechanical integrity of floor installations.[12] Consequently, the indictment asserts that Mr. Rovirosa’s firms have been awarded roughly $2.5 million price of PEMEX and PEP contracts.[13]

The indictment asserts jurisdiction over each defendants underneath the anti-bribery provisions of the FCPA on the premise that they’re “home issues,” as each defendants reside in Texas and are lawful everlasting residents of the US. A good portion of the proof described within the indictment is comprised of WhatsApp messages between Mr. Avila and PEMEX or PEP officers, a lot of which Mr. Avila allegedly despatched or acquired on the course of Mr. Rovirosa whereas Mr. Avila was throughout the Southern District of Texas. Within the cited messages, Mr. Avila and the PEMEX and PEP officers mentioned, amongst different issues, securing a positive audit decision for Mr. Rovirosa’s firms, awarding the roads and platforms contract to sure of Mr. Rovirosa’s firms, and awarding the mechanical integrity contract to different of these firms—in addition to the associated funds from Mr. Rovirosa and Mr. Avila.[14]  

Final week, the DOJ additionally issued its first FCPA declination pursuant to the CEP for the reason that pause in enforcement, declining to prosecute a U.S.-based firm for doable FCPA violations arising out of its brokers’ alleged actions in India.[15] In accordance with the letter, staff of the corporate’s subsidiary licensed improper funds to officers at state-owned banks in India to ensure that the banks to refer their clients to the subsidiary’s merchandise. The DOJ issued the declination on the premise of the corporate’s well timed and voluntary self-disclosure (which occurred in 2024, throughout the prior administration); its cooperation with the DOJ; the character and seriousness of the offense; the corporate’s remediation efforts; the absence of aggravating circumstances; and the corporate’s settlement to disgorge roughly $4.7 million in earnings from the conduct. The declination letter describes conduct very a lot within the heartland of circumstances that might have acquired a declination previous to the June Tips.

As we famous in our consumer alert relating to the DOJ’s June Tips,[16] the DOJ seems poised to proceed some FCPA enforcement exercise underneath the present administration. In gentle of the primary indictment and declination following the FCPA enforcement pause, firms ought to think about:

• Given the DOJ’s acknowledged prioritization of cartels and TCOs, the current indictment could also be a sign that conduct in Mexico and elsewhere in Latin America will obtain higher scrutiny by U.S. regulation enforcement authorities. Firms ought to be certain that acceptable compliance assets are dedicated to their actions within the area.
• The comparatively small whole worth of the alleged bribe funds within the indictment—$150,000—is a reminder that U.S. authorities aren’t limiting their consideration to “blockbuster” issues however fairly will nonetheless pursue run-of-the-mill circumstances related to people who have been pursued previous to the pause.  
• Whereas the June Tips famous that FCPA enforcement shouldn’t penalize “routine enterprise practices in different nations,”[17] the indictment referring to the availability of a Louis Vuitton purse, Hublot watches and a $26,000 treadmill means that “routine enterprise practices” don’t embrace luxurious items, and U.S. enforcers will proceed to pursue such circumstances the place items are of a price that arguably might affect the habits of the recipient.
• The DOJ’s reliance on Mr. Avila’s WhatsApp messages as the first supply of proof within the indictment ought to function a reminder of the significance positioned on “off channel” communications sources by the DOJ and that firms want to take care of clear insurance policies on the usage of messaging purposes for enterprise functions and retain data of acceptable communications.[18]
• Curiously, there is no such thing as a specific indication within the indictment that the related firms have been competing with U.S. firms or that U.S. firms have been harmed in any approach, regardless of the June Tips’ emphasis on limiting undue burdens on American firms that function overseas.[19] And, as famous above, any alleged connections to cartels appear unrelated to the conduct at concern.
• Equally, the declination bolsters the conclusion that the DOJ will proceed to pursue enforcement actions for conduct that falls outdoors the components outlined within the June Tips.
• Lastly, the declination demonstrates that the DOJ will proceed to concern declinations underneath the CEP for firms that self-disclose potential FCPA violations, totally cooperate, remediate and disgorge earnings referring to the improper conduct.

Future enforcement actions will little doubt present further perception into the DOJ’s concerns for opening, investigating and resolving FCPA circumstances in addition to how such concerns might or might not relate to the components outlined within the June Tips.[20]

[1] Exec. Order, Pausing Overseas Corrupt Practices Act Enforcement to Additional American Financial and Nationwide Safety (February 10, 2025), https://www.whitehouse.gov/presidential-actions/2025/02/pausingforeign-corrupt-practices-act-enforcement-to-further-american-economic-and-national-security/. See WilmerHale, President Trump and Lawyer Basic Bondi Announce Vital Shift in FCPA and Different Company Enforcement Priorities (February 11, 2025), https://www.wilmerhale.com/en/insights/client-alerts/20250211-president-trump-and-attorney-general-bondi-announce-significant-shift-in-fcpa-and-other-corporate-enforcement-priorities.

[2] Memorandum from the Deputy Lawyer Basic, Tips for Investigations and Enforcement of the Overseas Corrupt Practices Act (FCPA) (June 9, 2025), https://www.justice.gov/dag/media/1403031/dl.

[3] WilmerHale, Division of Justice Proclaims FCPA Tips (June 10, 2025), https://www.wilmerhale.com/en/insights/client-alerts/20250610-department-of-justice-announces-fcpa-guidelines.

[4] DOJ, Felony Division Company Enforcement and Voluntary Self-Disclosure Coverage, JUSTICE MANUAL § 9-47.120 (Up to date Could 12, 2025), https://www.justice.gov/prison/media/1400031/dl?inline. 

[5] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1.

[6] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1.

[7] Mot. To Impose Sure Situations of Launch, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 11, 2025), ECF No. 11. See additionally Indictment, United States v. Rovirosa; Press Launch, U.S. Dep’t of Justice, Two Mexican Nationals Charged for Bribing State-Owned Power Officers (August 11, 2025), https://www.justice.gov/opa/pr/two-mexican-nationals-charged-bribing-state-owned-energy-officials.  

[8] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶ 12.

[9] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶¶ 4-5.

[10] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶¶ 4-5.

[11] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶¶ 12, 15-16.

[12] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶ 13.

[13] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶ 14.

[14] Indictment, United States v. Rovirosa, 4:25-cr-00415 (S.D. Tex. Aug. 6, 2025), ECF No. 1, ¶¶ 18-21, 23-26, 29, 31-35, 40-51, 54-58.

[15] U.S. Division of Justice Letter (Aug. 7, 2025), https://www.justice.gov/prison/media/1410761/dl?inline.

[16] WilmerHale, Division of Justice Introduced FCPA Tips (June 10, 2025), https://www.wilmerhale.com/en/insights/client-alerts/20250610-department-of-justice-announces-fcpa-guidelines.

[17] Memorandum from the Deputy Lawyer Basic, Tips for Investigations and Enforcement of the Overseas Corrupt Practices Act (FCPA) (June 9, 2025), https://www.justice.gov/dag/media/1403031/dl.

[18] DOJ, Felony Division Company Enforcement and Voluntary Self-Disclosure Coverage, JUSTICE MANUAL § 9-47.120 (Up to date Could 12, 2025), https://www.justice.gov/prison/media/1400031/dl?inline.  

[19] Memorandum from the Deputy Lawyer Basic, Tips for Investigations and Enforcement of the Overseas Corrupt Practices Act (FCPA) (June 9, 2025), https://www.justice.gov/dag/media/1403031/dl.

[20] Along with the contributors listed under Emily L. Stark, Masha Goncharova and Walker Schulte Schneider additionally offered priceless help within the overview and drafting course of. 

Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, and Christopher Cestaro are Companions at WilmerHale. This text first appeared on the agency’s weblog.

The views, opinions and positions expressed inside all posts are these of the creator(s) alone and don’t characterize these of the Program on Company Compliance and Enforcement (PCCE) or of the New York College College of Legislation. PCCE makes no representations as to the accuracy, completeness and validity or any statements made on this web site and won’t be liable any errors, omissions or representations. The copyright of this content material belongs to the creator(s) and any legal responsibility with reference to infringement of mental property rights stays with the creator(s).