Insights

Washington – June 6, 2024: Crowell & Moring earned 78 rankings for 67 lawyers, as well as 41 national and statewide practice area rankings, in the Chambers USA 2024 guide. The rankings are driven by independent interviews of clients and lawyers at peer firms.

On February 10, 2025, President Trump issued an Executive Order, Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security (“Trump’s FCPA Order” or the “Order”), whose stated goal is “to restore American competitiveness and security by ordering revised, reasonable enforcement guidelines” for the FCPA. Fact Sheet: President Donald J. Trump Restores American Competitiveness and Security in FCPA Enforcement (“Fact Sheet”). Trump’s FCPA Order is part of his administration’s policy of “eliminating excessive barriers to American commerce abroad.”

On July 26, 2023, the U.S. Department of Justice (“DOJ”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Tri-Seal Compliance Note outlining their respective voluntary self-disclosure (“VSD”) procedures for potential violations of U.S. export controls and sanctions.  This announcement highlights the agencies’ focus on compliance with export controls, sanctions, and other U.S. national security laws, and reminds industry of the incentives for voluntarily disclosing potential violations, including mitigation of civil and criminal penalties. 

On July 21, 2023, the Biden administration announced that seven companies leading the development of artificial intelligence (AI) -- Amazon, Anthropic, Google, Inflection, Meta, Microsoft, and OpenAI -- have made voluntary commitments, which the companies agreed to undertake immediately, to help move towards safe, secure, and transparent development of AI technology. The goal of the voluntary commitments, or the “AI Agreement” as it is informally dubbed, is to establish a set of standards that promote the principles of safety, security, and trust deemed fundamental to the future of AI.

Since President Trump took office, several key FCPA developments have taken place that could impact your investigations and compliance programs. Attorneys in Crowell & Moring’s International Trade and White Collar & Regulatory Enforcement groups have teamed up for an engaging discussion on what companies can learn from these developments to date. Key topics to be discussed include: