Foreign executives are not spectators when dollars, issuers, or US competitiveness sit in the fact pattern. Unlike other law firms more focused on their relationship with prosecutors, we owe loyalty to only YOU. When you reach out to our law firm, you start with an initial risk-free consultation. You can ask us anything you want. Call 212 300 5196 - attorney on call, 24/7.
What changed in 2025.
After a February 2025 pause order narrative, DOJ issued June 9, 2025 guidelines prioritizing serious misconduct that undermines US interests rather than small greases.
Factors prosecutors weigh.
Cartel/TCO links, harm to identifiable US competitors, national security sectors, strong corrupt-intent indicia. AAG-level gating for new matters appears in guidance descriptions.
Nationality disclaimer vs practice.
Text says do not target by nationality. Commentary notes historically major cases often involved foreign companies - risk remains for non-US executives competing with US firms.
SEC civil track still exists.
DOJ guidelines are DOJ. SEC books-and-records/civil risk can continue on its own. Unlike mills that recycle one speech for every country, we map sec civil track still exists against your actual facts. This is a decision point on unknown where clients either keep leverage or give it away. For unknown, sEC civil track still exists has to be sequenced with the rest of the file - not handled as a slogan.
Issuer and USD nexuses.
List them. Brokerage, NY bank accounts, US issuer status of a parent - inventory coldly. Ask us anything before you act here. Risk-free consultation. Call 212 300 5196 - attorney on call, 24/7. Selective intake matters: we should only take on clients whom we can help on issuer and usd nexuses. For unknown, issuer and USD nexuses has to be sequenced with the rest of the file - not handled as a slogan.
Do not interview yourself by email.
Preservation under counsel. No clarifying memos to the file that become exhibits. Ask us anything before you act here. Risk-free consultation. Call 212 300 5196 - attorney on call, 24/7. Selective intake matters: we should only take on clients whom we can help on do not interview yourself by email. For unknown, do not interview yourself by email has to be sequenced with the rest of the file - not handled as a slogan.