Tag Archives: Erin G.H. Sloane

UK, French, and Swiss Enforcement Authorities Announce New Alliance

by Lloyd Firth, Dr. Jan-S. Wendler, Claire M. Guehenno, Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, Christopher Cestaro, and Lindsey Cullen

Top left to right: Lloyd Firth, Dr. Jan-S. Wendler, Claire M. Guehenno and Kimberly A. Parker. Bottom left to right: Jay Holtmeier, Erin G.H. Sloane, Christopher Cestaro and Lindsey Cullen (Photos courtesy of WilmerHale).

Summary

Anti-bribery and corruption agencies in the UK, France and Switzerland recently announced a shared commitment to tackling international bribery and corruption, by way of a new taskforce intended to strengthen collaboration.

This taskforce was announced by the UK’s Serious Fraud Office (SFO), France’s Parquet National Financier (PNF) and the Office of the Attorney General of Switzerland (OAG) at a meeting in London. Its founding statement notes “the significant threat of bribery and corruption” and states that its members recognise that “success relies on us working closely and effectively together”. It intends to deliver a working group for case cooperation and increased best practice sharing.

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President Trump and Attorney General Bondi Announce Significant Shift in FCPA and Other Corporate Enforcement Priorities

by Kimberly A. Parker, Matt Jones, Jay Holtmeier, Erin G.H. Sloane, Christopher Cestaro, Brenda E. Lee, Aaron M. Zebley and Emily L. Stark

Photos of authors.

Top left to right: Kimberly Parker, Matt Jones, Jay Holtmeier, and Erin Sloane. Bottom left to right: Christopher Cestaro, Brenda Lee, Aaron Zebley, and Emily Stark. (Photos courtesy of Wilmer Cutler Pickering Hale and Dorr LLP).

Soon after being sworn in, President Trump issued Executive Orders identifying top administration priorities: combating illegal immigration, drug cartels, and unlawful DEI practices. Taking a similar tack, on her first day in office, February 5, 2025, Attorney General Pamela Bondi instructed the US Department of Justice (“DOJ” or “Department”) to redirect its enforcement efforts from certain corporate crimes so that it could devote greater attention to the priorities outlined by the President. Across fourteen memoranda that promised more guidance to follow, Attorney General Bondi detailed changes that could transform the corporate enforcement landscape. This included a direction to the Foreign Corrupt Practices Act (“FCPA”) Unit of the DOJ to “prioritize investigations related to foreign bribery that facilitates the criminal operations of Cartels and TCOs,” or transnational criminal organizations, and to “shift focus away from investigations and cases that do not involve such a connection.”[1]

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Global Anti-Bribery Year-in-Review: 2022 Developments and Predictions for 2023

by Jay Holtmeier, Kimberly A. Parker, Erin G.H. Sloane, Christopher Cestaro, Meghan E. Kaler, and Caroline R. Geist-Benitez

Author photographs

From left to right: Jay Holtmeier, Kimberly A. Parker, Erin G.H. Sloane, Christopher Cestaro, Meghan E. Kaler, and Caroline R. Geist-Benitez. (Photos courtesy of Wilmer, Cutler, Pickering, Hale & Dorr LLP)

While Foreign Corrupt Practices Act (FCPA) enforcement activity has not come close to returning to the heights seen a few years ago, 2022 reflected significant increases from the prior year in both the number of cases against corporate defendants (eight vs. four) and the combined total of monetary penalties levied ($1.56 billion[1] vs. $459 million). Consistent with this upward trend of enforcement activity, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) continue to signal that anti-corruption enforcement is a priority and to provide further detail and clarification regarding their approach to corporate enforcement. Below are the key takeaways regarding FCPA enforcement in 2022 and trends to keep in mind as we look ahead to 2023.

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Global Anti-Bribery Year-in-Review: 2017 Developments and Predictions for 2018

by Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, Lillian Howard Potter, Tetyana V. Gaponenko, Victoria J. Lee, and Roger M. Witten

This past year marked the 40th anniversary of the U.S. Foreign Corrupt Practices Act (“FCPA”).  Since its enactment in 1977, the U.S. Department of Justice (the “DOJ”) has brought approximately 300 FCPA enforcement actions, while the U.S. Securities and Exchange Commission (the “SEC”) has brought approximately 200 cases.[1]  This anniversary year, the first year of the Trump administration, demonstrated that the FCPA continues to be a powerful tool in combating corruption abroad and encouraging compliance at global companies.

Below are six key take-aways regarding FCPA enforcement in 2017: Continue reading →