Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 17 MARCH 2025

Anticorruption And FCPA Enforcement: Takeaways And Lessons Heading Into 2025

Foley Hoag LLP
Explore more from Foley Hoag LLP

With active regulators around the globe, 2024 was a busy year for anticorruption enforcement and policy. In the U.S., we saw multiple high-profile new policies and updated guidance...

GlobalCriminal Law
Foley Hoag LLP
Foley Hoag LLP
Adam Safwat
Adam Safwat
Shrutih Tewarie
Shrutih Tewarie
Luciano Racco
Luciano Racco
Jack C. Smith
Jack C. Smith
Author LinkedIn connections

This is the second in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several weeks. A companion piece, "2024 in Review: Key Anticorruption Developments in the EU and France, with insights for 2025," can be found here. Our previous post, "Health Care Fraud Enforcement in 2025," can be found here.

With active regulators around the globe, 2024 was a busy year for anticorruption enforcement and policy. In the U.S., we saw multiple high-profile new policies and updated guidance from the U.S. Department of Justice ("DOJ"), while regulators worldwide picked up on trends to issue guidance on their key or newly available enforcement tools. We also learned lessons from significant enforcement activity at home and abroad. Below, we unpack the key trends from the past year with a look ahead to impacts in 2025.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

SEC Charges WhatsApp-Driven Crypto Fraud Schemes Totaling Over $15 Million

The SEC has charged two offshore entities with orchestrating sophisticated investment confidence scams that defrauded over 2,000 retail investors of at least $15.3 million through fake AI-powered crypto trading platforms. Using WhatsApp group chats, impersonated investment professionals, and fabricated regulatory filings, the defendants created elaborate schemes that promised guaranteed returns while stealing investor funds through shell companies and blocking withdrawal attempts with demands for additional
United StatesCriminal Law
Ballard Spahr LLP
Ballard Spahr LLP
Article

DOJ Announces 2026 National Health Care Fraud Takedown: 455 Defendants Charged In $6.5 Billion Enforcement Action

The Department of Justice's 2026 National Health Care Fraud Takedown charged 455 defendants in connection with $6.5 billion in alleged fraud schemes, marking an unprecedented scale of enforcement action. This whole-of-government approach leverages advanced data analytics and international cooperation to combat healthcare fraud across Medicare, Medicaid, and other federal programs. The enforcement action demonstrates heightened scrutiny of providers, aggressive asset forfeiture, and a focus on cases involvin
United StatesCriminal Law
Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP
Article

Prediction Markets — Legitimate Trading Or Gambling?

The rapid expansion of online prediction markets has created a regulatory gray area where consumers can effectively wager on sporting events even in states that prohibit traditional sports betting. As platforms like Kalshi, Polymarket, and Robinhood argue their services constitute futures trading rather than gambling, state attorneys general and the CFTC are locked in legal battles over jurisdiction and consumer protection.
United StatesCriminal Law
Klemchuk
Klemchuk
Article

California Requires Disclosure Of AI-Generated People In Advertising

California has enacted a groundbreaking AI disclosure law requiring advertisers to clearly identify when synthetic performers appear in their marketing materials. The legislation, set to take effect in 2027, includes a private right of enforcement that could potentially open the door to class action litigation against brands using AI-generated performers without proper disclosure.
United StatesMedia, Telecoms, IT, Entertainment
Foley Hoag LLP
Foley Hoag LLP
Article

Virginia’s Initial Draft Of Adult-use Marijuana Regulations – What You Should Know And What Questions Remain

Virginia's Cannabis Control Authority has released its initial draft of adult-use marijuana regulations, outlining application fees, license caps, and the approval process for the state's anticipated July 2027 launch of recreational cannabis sales. While the draft provides crucial details on licensing requirements and ownership restrictions, significant questions remain about the application timeline and evaluation criteria that will determine which entities receive coveted permits.
United StatesConsumer Protection
Foley Hoag LLP
Foley Hoag LLP
Article

Rising Cyberattacks On U.S. Water Infrastructure: Federal Guidance And Next Steps For Operators

Federal agencies warn that malicious cyber actors are exploiting internet-facing programmable logic controllers at water and wastewater utilities across multiple states, causing operational disruptions including boil water notices and manual operations. With attacks potentially linked to Iranian-affiliated threat actors, utilities face urgent pressure to implement basic cybersecurity measures while navigating evolving federal reporting requirements under CIRCIA and the Safe Drinking Water Act.
United StatesTechnology
Foley Hoag LLP
Foley Hoag LLP
Article

FDA Holds Landmark Public Hearing On The Future Therapeutic Use Of Psychedelic Drugs

The FDA, in collaboration with federal partners, held a landmark public hearing on September 14, 2026, to gather input on the future therapeutic use of psychedelic drugs, drawing over 18,000 registered attendees. This hearing represents one of the earliest implementations of Executive Order 14401, which directs federal agencies to expedite research, review, and approval of psychedelic drugs for serious mental health conditions.
United StatesFood, Drugs, Healthcare, Life Sciences
Foley Hoag LLP
Foley Hoag LLP
Article

UPDATE: DEA Publishes Registration Applications For Medical Marijuana Manufacturers, Distributors, And Analytical Labs

The DEA has opened new registration portals for medical marijuana manufacturers, distributors, and analytical labs, expanding beyond the dispensary registration that became available earlier this year. These applications require extensive business information and background disclosures, with fees ranging from $296 to $3,699, and may provide significant compliance and commercial benefits for cannabis businesses operating under state medical marijuana programs.
United StatesGovernment, Public Sector
Foley Hoag LLP
Foley Hoag LLP
Article

OCC Proposes BSA/AML And Sanctions Compliance Standards For Permitted Payment Stablecoin Issuers Under The GENIUS Act

The Office of the Comptroller of the Currency has proposed new regulations that would impose Bank Secrecy Act and sanctions compliance requirements on permitted payment stablecoin issuers under its jurisdiction. This rulemaking, coordinated with FinCEN and OFAC, establishes anti-money laundering, counter-terrorism financing, and sanctions program standards for stablecoin issuers as part of the broader implementation of the GENIUS Act framework.
United StatesFinance and Banking
Foley Hoag LLP
Foley Hoag LLP