Apr. 22, 2026

A Unified CEP: The VSD Calculus

After months of anticipation, the DOJ moved in March to reset the calculus for corporate self-reporting. Its new corporate enforcement policy (Unified CEP) closely resembles the Criminal Division’s 2025 policy update, while layering in changes meant to further incentivize voluntary disclosure of potential criminal violations. This second article in a two-part series on the Unified CEP evaluates the changes it introduces and whether and how the new policy might impact the voluntary self-disclosure calculus for companies. The first article analyzed just how “unified” the new policy really is. See our three-part series “2025 in Review”: White-Collar Enforcement the “Right Way” Remains a Priority (Dec. 17, 2025), DOJ Perspectives on How the Blanche Memo Restarted FCPA Enforcement (Jan. 14, 2026), and Impact on In-House Teams and Their Defense Counsel (Jan. 28, 2026).

How Asia‑Based Companies Should Respond as U.S. Enforcement Is Unpaused and APAC Regulation Hits Fast‑Forward

Despite ongoing risks of FCPA enforcement, for Asia-based companies, a more immediate and consequential development is the growth in activity by Asian regulators. Contrary to U.S. developments in 2025 and 2026 – marked by the pause and refocusing of FCPA enforcement efforts – anti-corruption enforcement has expanded in several key Asia-Pacific jurisdictions. In this guest article, Hogan Lovells partners Khushaal Ved and Matthew Sullivan, with associate Han Liang Lie, examine how Asia‑based companies should be reassessing their anti-corruption compliance efforts, given the evolving enforcement priorities of U.S. and Asian regulators. For more from Hogan Lovells, see “A Prescription for Corruption Risks in the Asian Healthcare Sector” (Jun. 18, 2025).

Balt Settlement: New DOJ Policies in Action

An alleged international bribery scheme has led to the DOJ declining to prosecute French medical device company Balt SAS and filing an indictment against two employees at the company’s U.S. subsidiary (Balt USA). At the same time, in France, the Parquet national financier entered into the French equivalent of a deferred prosecution agreement with Balt USA. This first article in a two‑part series examines what the declination and indictment reveal about the DOJ’s application of policies issued in the past year, including the Department‑wide Corporate Enforcement Policy issued in March 2026. The second article will look at the extraterritorial reach of the DOJ in FCPA cases, anti-corruption cooperation between the U.S. and France, best practices for mergers and how anti-corruption agencies are prioritizing investigations in the life sciences sector. See “What Does the FCPA EO Mean for European Enforcement?” (Apr. 23, 2025).

India Releases Rules for Its Digital Personal Data Protection Act

To operationalize the 2023 Digital Personal Data Protection Act (DPDPA), India’s first comprehensive data protection law, India’s Ministry of Electronics and Information Technology issued the law’s first set of regulations in November 2025 (Rules) and announced the effective dates for additional rules still to come. The Rules detail requirements on consent and notice, breach reporting, special protections for vulnerable groups (including children and persons with disabilities), cross‑border data transfers, and the structure and authority of the Data Protection Board of India, which adjudicates disputes over alleged misuse of personal data. This article unpacks the DPDPA as well as the Rules, and includes practical compliance guidance for companies as discussed by experts during a TrustArc panel. See “Diwali and Good Governance: Ethical Gift-Giving in India” (Sep. 24, 2025).

How Tech CLOs Think Attorneys Should Be Using AI

AI is fundamentally changing the practice of law, but many attorneys are confused or even frightened about what the technology may mean for their careers. Legal tech tools have evolved from basic spelling and grammar checks to document review and drafting, and now include sophisticated AI agents capable of handling complex tasks independently. Chief legal officers at technology companies are uniquely situated to see both sides of this evolution as they serve as the nexus between their business partners and outside counsel. This article summarizes key takeaways from a panel of lead counsel at Google, Anthropic, Liberty Mutual and IBM, who spoke at the recent ABA White Collar Crime Institute regarding how lawyers can adapt and thrive during this continuing wave of change. See “A Baker’s Dozen AI Governance Resolutions for 2026” (Jan. 14, 2026).

Winston Welcomes White Collar and Government Investigations Partner Duo

Winston & Strawn has welcomed two white-collar defense and compliance attorneys – Anne Murray and Guy Singer – as partners in its white collar and government investigations practice. The duo arrives from McDermott Will & Shulte and represents companies and individuals in matters involving fraud, bribery, corruption and ethics issues. For commentary from Murray, see “2025 in Review: Impact on In-House Teams and Their Defense Counsel” (Jan. 28, 2026). For commentary from Singer, see “What the Millicom DPA Portends for Joint Ventures and FCPA Enforcement” (Dec. 17, 2025).