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A New Sheriff in Town: State Attorneys General Take Action To Enforce Violations of the Foreign Corrupt Practices Act

By Toni Michelle Jackson, Agustin D. Orozco, Alexander J. Kramer, Derick D. Dailey & Lauren Arquette on April 15, 2025
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California Attorney General Rob Bonta advised California businesses that his office will enforce the Foreign Corrupt Practices Act (“FCPA”), marking a shift towards state enforcement of the FCPA in the wake of President Trump’s Executive Order. Click here to continue reading.

Photo of Toni Michelle Jackson Toni Michelle Jackson

Toni Michelle Jackson is a first-chair litigator whose extensive jury and bench trial experience is informed by over 15 years of government service. Clients rely on her to marshal the evidence presented during discovery and either win their case at summary judgment or…

Toni Michelle Jackson is a first-chair litigator whose extensive jury and bench trial experience is informed by over 15 years of government service. Clients rely on her to marshal the evidence presented during discovery and either win their case at summary judgment or try the case and win at trial. In particular, she leads class/collective actions, multidistrict litigations, and other complex litigation in federal and state courts. As chair of the State Attorneys General Practice Group, Toni provides advice and counsel to clients with State Attorneys General matters, including investigations, inquiries and litigation.

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Photo of Agustin D. Orozco Agustin D. Orozco

Agustin D. Orozco is a partner in the Los Angeles office and is a member of the firm’s White Collar & Regulatory Enforcement and Government Contracts groups. As a former federal prosecutor, Agustin is a skilled trial lawyer focused on directing complex white…

Agustin D. Orozco is a partner in the Los Angeles office and is a member of the firm’s White Collar & Regulatory Enforcement and Government Contracts groups. As a former federal prosecutor, Agustin is a skilled trial lawyer focused on directing complex white collar cases and investigations, handling contentious and sophisticated pretrial litigation, and successfully proving highly difficult cases at trial. Agustin’s background as a federal prosecutor and government contracts attorney leaves him uniquely situated to help clients where government contracts and white collar intersect.

Agustin represents clients in criminal and civil government investigations and enforcement actions. He also represents and counsels clients on matters involving federal, state, and local government contracts. Agustin has litigated civil False Claims Act (FCA) matters and other government contracts issues, such as disputes, claims, and terminations. He is also experienced in matters involving the Foreign Corrupt Practices Act (FCPA), including conducting investigations abroad and counseling clients on compliance issues.

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Photo of Alexander J. Kramer Alexander J. Kramer

Alexander J. Kramer is a partner in the White Collar and Regulatory Enforcement Group, bringing a wealth of experience from his distinguished career at the United States Department of Justice (DOJ). Alex has extensive experience in white collar crime and investigations, including the…

Alexander J. Kramer is a partner in the White Collar and Regulatory Enforcement Group, bringing a wealth of experience from his distinguished career at the United States Department of Justice (DOJ). Alex has extensive experience in white collar crime and investigations, including the Foreign Corrupt Practices Act (FCPA) and anti-corruption issues, health care fraud, significant fraud by government contractors, public companies, financial institutions, and other entities dealing with the DOJ, the U.S. Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), and related parallel enforcement actions.

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Photo of Derick D. Dailey Derick D. Dailey

Derick Dailey is a Counsel in Crowell’s State Attorney General, Litigation and Trial, and White Collar Investigations Practice Groups.

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Photo of Lauren Arquette Lauren Arquette

Lauren Arquette focuses her practice on litigation and trial, as well as white collar and regulatory enforcement matters. She also maintains an active pro bono practice in the areas of constitutional law and civil rights.

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  • Posted in:
    Administrative, Government
  • Blog:
    State AG Blog
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source
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