Tag Archives: Kimberly A. Parker

DOJ Announces First FCPA Enforcement Activity After Months-Long Pause

by Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, and Christopher Cestaro

Left to Right: Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, and Christopher Cestaro (photos courtesy of WilmerHale)

Over the past week, the U.S. Department of Justice (“DOJ”) unsealed its first Foreign Corrupt Practices Act (“FCPA”) enforcement action and issued its first declination since the pause in FCPA enforcement mandated by President Donald Trump’s February 10, 2025 Executive Order (“February Executive Order”)[1] and the subsequent issuance of updated FCPA enforcement guidelines, the Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) (“June Guidelines”).[2]  

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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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Biden: The Fight Against Foreign and Transnational Corruption Is a National Security Interest

by Kimberly A. Parker, Jay Holtmeier, Christopher Cestaro, John F. Walsh, Edward C. O’Callaghan, Ronald C. Machen, Lillian Howard Potter, Chavi Kenney Nana, Zachary Goldman, Mandy Fatemi, and Gemma Bateman

On June 3, 2021, President Biden issued a National Security Memorandum establishing the fight against corruption both at home and abroad as a core United States national security interest and directing the development of a 200-day interagency review designed to culminate in a report and recommendations on how the United States government and its partners can better combat corruption, enhance transparency in the global financial system and promote good governance. When combined with the anti-money laundering (AML) legislation that entered into force with the January 2021 bipartisan passage of the National Defense Authorization Act for Fiscal Year 2021 (NDAA)[1]—the most significant reforms to US AML laws since the 2001 adoption of the USA PATRIOT Act—and a review of sanctions policy conducted by the Treasury Department, the Memorandum may lead to a heightened focus on illicit financial activity and corruption and may ultimately result in additional resources being allocated to anti-corruption and AML enforcement. Continue reading →

FCPA Risks for Renewable Energy in Latin America

by John F. Walsh, Alejandro N. Mayorkas, Kimberly A. Parker, Jay Holtmeier, Michael Connor, Lillian Howard Potter, Heidi K. Ruckriegle, and Noah Guiney 

The renewable energy market[1] in Latin America is booming, and the region’s natural resources make it one of the most attractive areas in the world for investment. Latin American countries, including Brazil, Mexico and Chile, have been recognized as some of the top global renewable energy markets. Between 2010 and 2015, $80 billion was invested in green energy in Latin America, excluding large-scale hydropower.[2] Further regulatory and policy developments, such as the deregulation of national energy markets and the desire to meet the goals of the Paris Climate Accord, have only increased this trend.[3] Prior to the onset of the COVID-19 pandemic, 2020 had been a banner year for renewable energy development in Latin America. Experts predict that in 2020, Mexico will see 11 new wind farms begin operation, representing a $1.6 billion investment.[4] In Brazil, approximately 3.2 GW of unsubsidized solar projects have been permitted and are currently in development.[5] Not to be outdone, Colombia recently announced that there are 9.47 GW of solar projects currently underway.[6] While the COVID-19 pandemic has upended the global economy—including the renewable energy market globally[7] and in Latin America—the region’s economic, political and geographic characteristics suggest that wind and other renewable power sources will have an increasingly important role to play in its energy mix.

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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 →

Global Magnitsky Sanctions Target Human Rights Abusers and Government Corruption Around the World

by David S. Cohen, Kimberly A. Parker, Jay Holtmeier, Ronald I. Meltzer, David M. Horn, Lillian Howard Potter, and Michael Romais

On December 20, 2017, President Trump issued a new Executive Order (PDF: 235 KB) (EO) targeting corruption and human rights abuses around the world.

The EO implements last year’s Global Magnitsky Human Rights Accountability Act (the Global Magnitsky Act), which authorized the president to impose sanctions against human rights abusers and those who facilitate government corruption.[1] The US Department of the Treasury’s Office of Foreign Assets Control (OFAC), which will administer the EO, also added 15 individuals and 37 entities to its Specially Designated Nationals and Blocked Persons List (SDN List). Continue reading →