DOJ Issues Transformative FCPA Guidelines Prioritizing U.S. National Interests
On June 9, 2025, the Department of Justice under Deputy Attorney General Todd Blanche released updated Foreign Corrupt Practices Act (FCPA) guidelines, effectively ending the four-month enforcement pause instituted by a Trump administration executive order. The new guidelines fundamentally reshape anti-corruption enforcement by: (1) prioritizing investigations directly tied to U.S. national security and economic interests, (2) focusing on individual criminal misconduct rather than broad corporate liability, and (3) requiring high-level DOJ authorization for new investigations. Prosecutors are now instructed to target cases involving cartels, transnational criminal organizations, and serious misconduct that demonstrably threatens U.S. interests.
Key Actors
Sources (4)
- DOJ FCPA Guidelines End the Enforcement Pause and Shift Focus to U.S. Interests (2025-06-09)
- Updated FCPA Enforcement Guidelines (2025-06-09)
- FCPA Enforcement: Back With a Twist? DOJ Issues New FCPA Guidelines Following Trump Executive Order (2025-06-09)
- The FCPA Pause Is Over: Trump DOJ Issues Long-Awaited FCPA Investigations and Enforcement Guidelines (2025-06-09)
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