March 28, 2025
Law360
Jon Sale, co-chair of the firm's White Collar & Government Investigations Practice Group, was quoted in a Law360 article, "FCPA 'Purgatory' Frustrates White Collar Bar, Anxious Clients," published on March 27. The article discusses the uncertainty lawyers and clients face due to a pause in Foreign Corrupt Practices Act enforcement following President Trump's executive order, leaving them unsure how to proceed.
Sale told Law360 that "doubt about whether an 'acting head has the same authority as an assistant AG' has spurred some white collar attorneys to appeal up to Deputy Attorney General Todd Blanche, the No. 2 at the Justice Department, as they seek to resolve clients' FCPA matters."
"In my experience, when the DAG is considering whether to grant a meeting, that office asks the Criminal Division what the investigation is about," Sale said. "There may be problems getting an informed response from the Criminal Division, because of the absence of a permanent assistant AG, even though the acting head of the Criminal Division is a respected career professional."
These materials have been prepared for informational purposes only and are not legal advice. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. Internet subscribers and online readers should not act upon this information without seeking professional counsel.