Acting Assistant Attorney General Galeotti On FCPA Enforcement
Last week Acting Assistant Attorney General Matthew Galeotti gave this speech stating that “white-collar enforcement remains a priority for the Criminal Division.”
Galeotti identified “a few key priority areas for the Division” including foreign corruption.
He stated:
“Following the President’s Executive Order in February, the Deputy Attorney General issued FCPA enforcement guidelines in June, which set forth non-exhaustive priority areas for the Department’s prosecutors. As the DAG announced, he led a process reviewing all such matters, and the Division will firmly — but fairly — prosecute foreign bribery cases consistent with the Guidelines.
Many Of The Topics Discussed In The FCPA Guidelines Are Not New
On June 9th, DOJ Deputy Attorney General Todd Blanche issued this memo to the head of the DOJ Criminal Division titled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act.”
At first blush, it may seem like there are many new topics in the Guidelines.
What is perhaps new is that these topics are actually written down in a DOJ policy document, but as highlighted in this prior and future posts, many of the topics discussed in the Guidelines have been happening before our eyes for several years.
For instance, the Guidelines state:
Many Of The Topics Discussed In The FCPA Guidelines Are Not New
On June 9th, DOJ Deputy Attorney General Todd Blanche issued this memo to the head of the DOJ Criminal Division titled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act.”
At first blush, it may seem like there are many new topics in the Guidelines.
What is perhaps new is that these topics are actually written down in a DOJ policy document, but as highlighted in this post and future posts, many of the topics discussed in the Guidelines have been happening before our eyes for several years.
For instance, the Guidelines state:
DOJ Criminal Division Head Galeotti On …
Yesterday, DOJ Criminal Division head Matthew Galeotti gave this speech in which talked about the DOJ’s recently released “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act.” (See here for the prior post) as well as the DOJ “White Collar Enforcement Plan” released last month (see here for the prior post).
Galeotti began:
“The Deputy Attorney General sent me a memorandum, which he publicly released, detailing the new FCPA Enforcement Guidelines called for by the President’s Executive Order. These Guidelines provide evaluation criteria and a non-exhaustive list of factors to balance when deciding whether to pursue an FCPA case.”
DOJ Talk Over The Years
As highlighted in this prior post, several of the issues discussed in President Trump’s February 10th Executive Order “Pausing” FCPA enforcement had been percolating for many years and discussed by many individuals.
The same is true regarding several of the issues highlighted in the DOJ’s recent policy memo titled “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime.” (See here for the prior post).
This is particularly true when it comes to the “efficiency” of DOJ investigations.
The recent policy memo states: