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    May 21, 2025

SFO Co‑Operation Guidance: A Hard Sell for Self-Reporting

On April 24, 2025, the SFO issued External Guidance on Corporate Co-Operation and Enforcement in relation to Corporate Criminal Offending (2025 Guidance), which seeks to provide additional clarity and certainty to companies considering self-reporting criminal wrongdoing. The 2025 Guidance has plenty of wiggle room built in, however, leaving companies with tough decisions to make about whether to come forward. The Anti-Corruption Report spoke with practitioners in London about the implications of the 2025 Guidance. This first article in a two-part series discusses the impact on self-reporting. Part two will examine the SFO’s expectations for corporate cooperation. See “The International Anti-Corruption Taskforce and U.S. FCPA Enforcement: A Look Ahead” (May 7, 2025).

How Designating TCOs As Terrorist Organizations Creates Risks for Financial Institutions and Beyond

President Donald Trump recently signed an executive order (TCO EO) authorizing the designation of international narcotics cartels and other transnational criminal organizations (TCOs) as Foreign Terrorist Organizations. While U.S. law enforcement has long targeted cartels and TCOs for illegal narcotics sales and jeopardizing safety in the United States, the TCO EO has opened a new front in this fight, and one that is likely to escalate pressure on businesses, financial institutions, and cryptocurrency exchanges and issuers. In a guest article, Boies Schiller partners Dan Boyle and John Kucera explain how this change is expected to alter the landscape of seizure and forfeiture not only for cartels and TCOs themselves, but for businesses and financial institutions across the Latin American region. See “Reference Guide to 2025 Executive Orders for Compliance Professionals” (Apr. 9, 2025).

Will France Continue Aggressive Bribery Enforcement Efforts in the Wake of a U.S. “Pause”?

Over the last decade, France has reinvented itself as a leader in the global fight against corruption, with novel legal frameworks and an active enforcement culture. With U.S. FCPA enforcement on pause, France may be poised to take a more prominent role on the global enforcement stage. In a guest article, Proskauer partner Bryan Sillaman, along with counsel Sergon Sancar and associates Salomée Bohbot, Santiago Ramirez-Reyes, and Mélinée Aprikian, discuss how France has an opportunity to further distinguish itself as an influential partner in the global fight against corruption. See “How the New DOJ and PNF Corporate Enforcement Guidelines Affect Self-Reporting, Cooperation and Remediation” (Mar. 29, 2023).

How UMass Leveraged ERM Tools to Improve Procurement

Third-party risk management in a large organization with many suppliers can be unwieldy and challenging. However, coordinating efforts with the organization’s enterprise risk management (ERM) team can generate synergies between the two functions and drive efficiency. In a recent panel during a Society of Corporate Compliance and Ethics conference, Christine Packard, the assistant vice president for enterprise risk management at the University of Massachusetts (UMass), and Michael Durkin, chief procurement officer at UMass and head of the unified procurement services team, explained the benefits of their teams working together. See “Understanding and Mitigating Risk of Organizational Conflicts of Interest for Government Vendors” (Mar. 13, 2024).

DOJ Guidance on Bulk Sensitive Data Rules: Enforcement Grace Period and Prohibited Transactions

The DOJ has issued guidance to facilitate compliance with its final rules, referred to as the Data Security Program (DSP), implementing former President Biden’s Executive Order on Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern. Though much of the guidance material rearticulates language in the DSP, there was some notable new compliance information for organizations. This two-part article series highlights the key elements of the guidance, with commentary from Edward McNicholas, a partner at Ropes & Gray. This first installment covers the enforcement grace period, definitions of bulk data and covered persons, and prohibited transactions. Part two will distill guidance on restricted transactions, recordkeeping, reporting requirements, licenses and advisory opinions. See “Examining DOJ’s Final Rules on Access to Government and Sensitive U.S. Personal Data” (Feb. 12, 2025).

Former DOJ Litigation Chief Joins Hogan Lovells in D.C.

Hogan Lovells has welcomed former DOJ Litigation Chief Jerrob Duffy as a partner in its investigations, white collar and fraud practice in Washington, D.C. He arrives from Squire Patton Boggs. For insights from Hogan Lovells, see “What Does the FCPA EO Mean for European Enforcement?” (Apr. 23, 2025).

Mitchell Sandler Welcomes Veteran Federal Prosecutor in D.C.

Seth Waxman has joined Mitchell Sandler as a partner and head of the firm’s newly launched government investigations and white collar criminal practice group in Washington, D.C. He arrives from Dickinson Wright. For commentary from Waxman, see “Eletrobras’ Many Facets: Victim, Wrongdoer, State-Owned Entity, Issuer and More” (Jan. 9, 2019).

Most-Read Articles

Women to Watch: Contributions, Achievements and Observations of Outstanding Female Professionals

To mark International Women’s Day, women editors and reporters at ION Analytics interviewed outstanding women in the industries and jurisdictions we cover. In this part, Law Report Group editors Jill Abitbol, Robin L. Barton and Megan Zwiebel profile notable women in data privacy, cybersecurity, private funds and anti-corruption law, including Anne-Gabrielle Haie, Jessica Lee, Micaela McMurrough, Laura Perkins, Amanda Raad, Madelyn Calabrese, Ranah Esmaili and Genna Garver. Enjoy reading their inspiring remarks here.

Spotlight on Trailblazing Women

To mark International Women’s Day 2024, women editors and reporters of ION Analytics interviewed outstanding women in the industries and jurisdictions we cover. In this part, Jill Abitbol, Managing Editor of the Cybersecurity Law Report and Anti-Corruption Report, features notable women in data privacy, cybersecurity, white collar defense, compliance and anti-corruption law, including Christina Montgomery, Leslie Shanklin, Palmina Fava, Alexandra Ross and Lucinda Low. Enjoy reading their inspiring remarks here.

Ion Analytics' Spotlight on Trailblazing Women

In honor of International Women’s Day, some of ION Analytics' editorial teams led by women interviewed notable women in the markets and industries we cover. This part highlights notable women in compliance and hedge fund, data privacy and cybersecurity, and anti-corruption law, including Amii Barnard-Bahn, Abigail Bell, Genna Garver, Jane Horvath, Barbara Li, Amy Mushahwar, Mara Senn and Carol Widger. The interviews are here.

Data, Culture, ESG and Scope Creep with GM's Michael Ortwein

The Anti-Corruption Report spoke with chief compliance officer and assistant general counsel at General Motors, Michael Ortwein, who shared his insights on top-of-mind issues in advance of his participation in ACI's FCPA Conference. 

The full video is here. The associated article is here.

Corporate Compliance and Enforcement Hot Topics With IBM VP Una Dean

The Anti-Corruption Report spoke with IBM's vice president and assistant general counsel of investigations Una Dean, who co-chaired ACI's FCPA conference, about a range of hot compliance topics. 

The video is here

Quick Take on FARA

https://acuris.wistia.com/medias/wmb5vyeq2f

The Anti-Corruption Report discusses the Foreign Agents Registration Act (FARA) in this short video. For our three-part guide to FARA and the new risk environment, see here.

ACR Editor Discusses Using Artificial Intelligence to Support Anti-Corruption Compliance

Senior Editor Megan Zwiebel recently appeared on a podcast with Perkins Coie White Collar & Investigations partners Gina LaMonica and Caryn Trombino, who discussed the use of AI in compliance programs, including trends in AI-based compliance, steps companies can take to utilize AI in their compliance programs, and how regulators view the use of data and AI in compliance programs. Listen to the podcast here.

ACR Q3 Editorial Update

Listen to our Fall Editorial Update for a discussion of recent enforcement actions; enforcement trends and policies; and top-of-mind issues, such as internal investigations and hotlines, all in under 15 minutes. Register here.

ACR and CSLR Spring Update 2020

​​​​The Senior Editors of the Anti-Corruption Report and the Cybersecurity Law Report recently teamed up to present an update on the trends and hot topics in the anti-corruption, cybersecurity and data privacy spaces since the beginning of the year and what the publications will be focusing on in the coming months. A complimentary download of the webinar is available here.

Upcoming Webinar to Explore Best Practices for AML Compliance by Private Fund Managers

Please join our sister product, the Hedge Fund Law Report, on Thursday, May 30, 2019, at 11:00 a.m. EDT, for a complimentary webinar discussing the key components of a robust anti-money laundering program. To register for the webinar, click here.

ACR Webinar: The Art and Science of Transaction Monitoring: A Google Perspective

Transaction monitoring can help a company identify problem areas and assess how well its compliance program is working. Please join the Anti-Corruption Report for a complimentary webinar on May 2, 2019, from 1 p.m. to 2 p.m. EDT, where Senior Editor Megan Zwiebel will interview Google global ethics & compliance senior counsel Therese Lee and forensic program manager Aditya Yerramilli about how Google handles the art and science of transaction monitoring. Registration information is here.

ACR Webinar: Mitigating Risk in Argentina After the Notebooks Scandal

Doing business in a country that is embroiled in a mega-scandal can be treacherous. This is particularly true when the local business community is slow to get on the compliance bandwagon, as has been the case in Argentina while the Notebooks Scandal has been unfolding. Please join the Anti-Corruption Report on April 17, 2019, from 1:00 p.m. to 2:00 p.m. EDT for a complimentary webinar in which Editor-in-Chief Nicole Di Schino will discuss how to mitigate risk in light of the developing scandal with Argentinian attorney Guillermo Jorge, a partner at Bruchou, Fernandez Madero & Lombardi, and Barrick Gold’s Jonathan Drimmer. To register, please click here.