Insights Search

On June 9, 2025, Deputy Attorney General Todd Blanche announced that the U.S. Department of Justice (“DOJ” or the “Department”) will resume investigating and prosecuting violations of the U.S. Foreign Corrupt Practices Act (the “FCPA”) with a decidedly new “America First” approach to enforcement.

On May 19, 2025, Deputy Attorney General Todd Blanche issued a memorandum announcing the creation of the Department of Justice’s (DOJ) Civil Rights Fraud Initiative (the Initiative), which directs DOJ attorneys to utilize the False Claims Act (FCA), 31 U.S.C. § 3729 et seq., to combat knowing violations of civil rights law and the false certification of compliance with such laws by recipients of federal funds such as educational institutions and federal contractors.

Zach Terwilliger outlines his transition from US Attorney to partner at Vinson & Elkins LLP, emphasizing the importance of a structured integration plan, proactive business development, and adapting to a client-focused mindset. He highlights how skills from government service such as crisis management, leadership, and perseverance translate effectively to private practice.

V&E lawyers discussed FCPA and anticorruption enforcement and how DOJ’s new memos demonstrate the Administration’s shifting white collar enforcement priorities.

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (“DOJ” or the “Department”) issued a series of significant policy changes outlining the Trump administration’s new approach to white-collar enforcement.

Despite signs of a retrenchment in some of the traditional areas of white collar enforcement under the Trump administration, the U.S. Department of Justice’s (“DOJ”) enforcement of the civil False Claims Act (“FCA”) appears likely to proceed at a steady and aggressive pace amid a renewed focus on waste, fraud, and abuse and a recent jump in the number of new qui tam actions.

On April 2, 2025, President Donald Trump announced a new tariff regime under the International Emergency Economic Powers Act of 1977 (“IEEPA”), citing national security concerns. This regime includes a 10 percent baseline tariff for all countries and higher “reciprocal tariffs” for approximately 90 countries, effective April 5, and April 9, 2025, with additional potential tariffs threatened in the future. The new tariffs would significantly impact corporations, particularly those with supply-chain exposure in China and other Southeastern Asian countries.

On April 28, 2025, the U.S. Attorney’s Office for the Eastern District of Virginia (“EDVA”) and the U.S. Department of Justice’s (“DOJ”) Civil Rights Division (“CRT”) announced the formation of the Eastern District of Virginia Equal Access to Banking Task Force.

Vinson & Elkins, Gray Analytics, and keynote speaker Stacy Bostjanick of the Department of Defense (DoD) Office of the Chief Information Officer discussed the new CMMC program.

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”).

As we previously discussed, on January 7, 2025, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction delaying the implementation of the Corporate Transparency Act’s (“CTA”) reporting requirements (Smith, et al. v. U.S. Department of the Treasury).

Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt Practices Act of 1977, as amended (the “FCPA”), and signaled a coming shift in how the statute will be enforced in the future.