News & Analysis as of

Significant Transnational Criminal Organization Executive Orders Enforcement Priorities

Baker Donelson

Update: DOJ Issues Guidelines for Protectionist FCPA Enforcement

Baker Donelson on

In February, the White House issued an Executive Order "pausing" Foreign Corrupt Practices Act (FCPA) enforcement for 180 days, to "further American economic and national security."1 On June 9, Deputy Attorney General Todd...more

Dorsey & Whitney LLP

New DOJ Guidelines Mark the End of the FCPA Enforcement “Pause”

Dorsey & Whitney LLP on

On June 9, 2025, Department of Justice (“DOJ”) Deputy Attorney General Todd Blanche issued the highly anticipated “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (the “Guidelines”),...more

Latham & Watkins LLP

DOJ Focuses FCPA Enforcement With New Guidelines

Latham & Watkins LLP on

DOJ issues updated guidelines, ending temporary “pause” on FCPA enforcement and focusing potential enforcement on priority areas. On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the Guidelines)...more

Benesch

New FCPA Guidance Underscores Importance of Internal Compliance for Companies Doing Business Abroad

Benesch on

On June 9, 2025, Todd Blanche, Deputy Attorney General for the United States Department of Justice, published guidelines for investigations and prosecutions under the Foreign Corrupt Practices Act (FCPA). These guidelines...more

Paul Hastings LLP

New DOJ FCPA Guidelines Target Cases Linked to US Strategic Interests

Paul Hastings LLP on

On June 9, U.S. Deputy Attorney General Todd Blanche issued a memorandum entitled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA),” which establishes guidelines to ensure that FCPA...more

Latham & Watkins LLP

Trump Administration Targets Cartels With First Wave of Terrorism Designations

Latham & Watkins LLP on

The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....more

BakerHostetler

Why Your Company Still Needs to Care About the FCPA (& FEPA)

BakerHostetler on

This shift in FCPA enforcement priorities is the latest move by the administration in its all-out war against cartels and TCOs that pose a threat to U.S. national security and its stated America First agenda. Additionally,...more

Dorsey & Whitney LLP

Should Your Company Shut Down Its Anti-Corruption Compliance Program and Start Paying Bribes? Here Are a Few Reasons to Think...

Dorsey & Whitney LLP on

On February 10, 2025, President Trump issued a new Executive Order (“EO”) titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” This EO comes on the tail of Attorney...more

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