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DOJ Issues Anticipated FCPA Enforcement Guidelines with Focus on US Interests, Individual Accountability

The US Department of Justice has issued new guidance regarding enforcement of the Foreign Corrupt Practices Act (FCPA) in a June 9 memorandum from Deputy Attorney General Todd Blanche. The memorandum formalizes a shift in...more

Cartels, TCOs, ‘Instrumentalities of a Government’: Reassessing FCPA Risk Amid Shifting US Enforcement Priorities

Whether cartels do or do not qualify as “instrumentalities of a government” under current FCPA law or based on the AG’s forthcoming revised FCPA guidance, their entanglement with corrupt officials and influence over local...more

Newly Confirmed AG Pam Bondi Issues Directive Limiting Scope of FCPA Enforcement

Newly Appointed US Attorney General Pam Bondi issued a directive shifting the focus of Foreign Corrupt Practices Act investigations and cases away from those that do not involve criminal operations of cartels and...more

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