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    Jun. 18, 2025

Assessing the Criminal Division’s New Enforcement Focuses

The anti-corruption and compliance bar has been in a state of uncertainty since President Trump took office and paused enforcement of the FCPA. DOJ Criminal Division Head Matthew Galeotti brought a bit more solidity to the landscape when he announced that, going forward, the Criminal Division will prioritize cases in 10 “high-impact” areas. There is some overlap between the 10, and they can be consolidated into five broad categories: (1) healthcare fraud; (2) trade compliance; (3) financial crime (particularly crimes that relate to China); (4) crimes involving cartels, transnational criminal organizations and foreign terrorist organizations; and (5) bribery and corruption. This article assesses the impact of the new priorities. See our two-part series on the FCPA Executive Order: “The Future of U.S. Enforcement” (Mar. 12, 2025), and “Staying the Course in the Face of Continued Risk” (Mar. 26, 2025).

A Prescription for Corruption Risks in the Asian Healthcare Sector

Bribery, corruption and misconduct risks are particularly high in the life sciences space – pharmaceuticals, medical devices, medical technologies and medical advisory – given the intersection between emerging markets, government officials, reliance on third parties, rising medical costs, growing populations, wage differentials and the necessity of the services. The risks are noticeably pronounced in China, Vietnam and Indonesia: three Asian countries where rapid economic growth, significant healthcare spending and complex regulatory environments have created fertile ground for compliance challenges in this sector. In this guest article, Hogan Lovells attorneys based in Asia undertake a cross-jurisdictional review of the healthcare sector for three of Asia’s largest economies; identify how, where and why corruption and compliance risks may manifest; and recommend risk mitigation steps for companies. See “Internal Investigations in the Life Sciences Industry” (Jul. 8, 2020).

AI Governance: Striking the Balance Between Innovation, Ethics and Accountability

To fully unlock AI’s potential, organizations should move beyond fear or complacency and embrace a framework that balances innovation with responsibility. Achieving this balance requires robust AI governance, seamless integration of risk management into existing processes, and a culture that values transparency, fairness and accountability. In this guest article, Pari Sarnot, who, at the time of writing, was a member of the cyber privacy and risk advisory practice at Grant Thornton Advisors LLC, and is currently a product privacy manager at Meta, offers a practical roadmap of key considerations for establishing an AI governance program, including the role of trustworthy AI and steps to take in the AI solution lifecycle development process. The views Sarnot expresses in this article are her own and do not represent those of current or previous employers. See “DOJ’s 2024 Edits to the ECCP: Some History and AI Expectations” (Nov. 6, 2024).

Skills and Qualities of Effective Compliance Officers

The role of the CCO has evolved significantly in recent years, extending across industries. Contemporaneously, salaries have increased, though growth in compensation slowed in 2025 as compared to 2024, according to BarkerGilmore’s 2025 CCO Compensation Report. This article synthesizes relevant findings from the report and distills insights from the firm’s webinar, which included professionals from Radical Compliance and Spark Compliance Consulting, on the current market for CCOs, compensation trends, relevant skills and experience, and challenges facing dual-hatted GC-CCOs. See “To Work Effectively, CCOs Need Authority, Autonomy and Information” (Nov. 6, 2024).

Insights From a Local Attorney on Corruption in Mexico

Transparency International’s Corruption Perceptions Index for 2024 gave Mexico its worst score yet, at 26, despite more than a decade’s worth of efforts to curb corruption. Meanwhile, earlier this year, the U.S. State Department designated eight cartels and transnational criminal organizations, most of them Mexican, as foreign terrorist organizations. Together, these developments have complicated the business landscape for companies operating in, or reliant on goods and services from, Mexico. Ricardo Cacho, a counsel at Von Wobeser y Sierra, spoke with the Anti-Corruption Report about the current state of Mexican anti-corruption law, the impact of the recent U.S. policy changes and how companies should be thinking about risk mitigation. See “Managing Corruption at the Local Level in Latin America” (Jul. 3, 2024).

Palmina Fava Is the New GC of Ben & Jerry’s

Palmina Fava will be making the sweet move to in-house counsel, joining the ice cream conglomerate that will be spun off from Unilever as of July 1, 2025. She joins the Magnum Ice Cream Company as chief integrity officer and head of litigation and will serve as GC of Ben & Jerry’s. For commentary from Fava, see “The Price Is Right? How DOJ’s New Whistleblower and NPA Policies Could Bring Unexpected Costs” (Jun. 19, 2024).

Rod Rosenstein Joins Baker McKenzie

Baker McKenzie has added former U.S. Deputy AG Rod Rosenstein as a partner in its litigation and government enforcement practice group in Washington, D.C. He is also chair of the firm’s national security practice. He arrives from King & Spalding. For commentary from Rosenstein, see “Vitol Settles First CFTC Action Involving Foreign Corruption, Defers Prosecution With DOJ” (Dec. 16, 2020).

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Women to Watch: Contributions, Achievements and Observations of Outstanding Female Professionals

To mark International Women’s Day, women editors and reporters at ION Analytics interviewed outstanding women in the industries and jurisdictions we cover. In this part, Law Report Group editors Jill Abitbol, Robin L. Barton and Megan Zwiebel profile notable women in data privacy, cybersecurity, private funds and anti-corruption law, including Anne-Gabrielle Haie, Jessica Lee, Micaela McMurrough, Laura Perkins, Amanda Raad, Madelyn Calabrese, Ranah Esmaili and Genna Garver. Enjoy reading their inspiring remarks here.