Simpson Thacher Attorneys Author Law360 Article on New FCPA Enforcement Guidelines
06.17.25
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Global Co-Heads of Simpson Thacher’s Government and Internal Investigations Practice Jeff Knox and Nick Goldin, and Counsel David Caldwell, authored a Law360 article titled, “FCPA Enforcement Is Here To Stay, But It May Look Different.” The article detailed Deputy Attorney General Todd Blanche’s recent memorandum, which enumerated a non-exhaustive list of factors that prosecutors will consider when determining whether to initiate an FCPA investigation or prosecution. It further highlighted that there will be a fundamental shift in the DOJ’s exercise of prosecutorial discretion and its enforcement objectives. The article also provided insights into how white collar investigations will be approached going forward, and guidance for companies subject to investigations.
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