Insights

Washington – February 27, 2023: Global Investigations Review has named Crowell & Moring’s Investigations and White Collar & Regulatory Enforcement groups to its prestigious GIR 100 list, an annual guide to the world’s leading cross-border investigations practices. Based on extensive research, GIR selects 100 firms from around the world that it deems most able to handle sophisticated cross-border government-led and internal investigations. This is the eighth consecutive year that Crowell & Moring has made the list.

On June 9, 2025, U.S. Department of Justice (“DOJ”) Deputy Attorney General Todd Blanche issued new Foreign Corrupt Practices Act (“FCPA”) enforcement guidelines (“the Guidelines”). DOJ issued the Guidelines in response to the Trump Administration’s February 2025 Executive Order (“EO”), which paused FCPA enforcement pending the issuance of new guidance from the Attorney General. The new Guidelines resolve lingering doubts about the future of FCPA enforcement under the Trump administration and provide important insights into the key factors DOJ will consider when deciding whether to pursue FCPA investigations or enforcement actions.

On 24 April 2025, the UK Serious Fraud Office (“SFO”) unveiled its new External Guidance on Corporate Co-Operation and Enforcement in relation to Corporate Criminal Offending (the “Guidance”)[1]to enhance corporate compliance, transparency and cooperation in combatting fraud, bribery and corruption in the UK. This comprehensive guidance is critical for both UK-based entities and international companies operating under UK jurisdiction.

Congress recently announced an investigation into the role of certain financial technology (“FinTech”) firms and partner banks in issuing allegedly fraudulent Paycheck Protection Program (“PPP”) loans.  The May 28th press release from the House of Representatives’ Select Subcommittee on the Coronavirus Crisis cited recent reporting which “found that FinTechs and their bank partners handled 75 percent of the approved PPP loans that have been connected to fraud by DOJ, despite facilitating just 15 percent of PPP loans overall.”  This announcement follows closely on the heels of the Subcommittee’s March hearing on “Rooting Out Fraud in Small Business Relief Programs,” and marks yet another example of the scrutiny pandemic relief program participants will continue to face from regulators.  It also confirms that – despite severely relaxed underwriting requirements – FinTechs and their partner banks, in addition to PPP loan recipients, should be prepared for government scrutiny. 

Crowell & Moring's New York based White Collar and Regulatory Enforcement attorneys Rebecca Ricigliano and Arlen Pyenson will speak at the New York Women’s Bar Association (NYWBA) Criminal Law and Federal Practice Committees’ April 19th CLE Program. The CLE, which will be hosted by Crowell & Moring’s New York Office, will discuss “When A Civil Enforcement Action Turns Criminal.”