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
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
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
The pause on enforcement of the Foreign Corrupt Practices Act (FCPA) is over. On June 9, the Deputy Attorney General of the Department of Justice (DOJ) issued a memorandum (the June 9 Memorandum) establishing new enforcement...more
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
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
On February 5, 2025, Attorney General Pamela Bondi issued a memo requiring DOJ’s Foreign Corrupt Practice Act (“FCPA”) Unit to “prioritize investigations related to foreign bribery that facilitates the criminal operations of...more
On January 20, President Trump issued an Executive Order designating certain international cartels as Foreign Terrorist Organizations (FTOs) or Specially Designated Global Terrorists (SDGTs). ...more
President Trump Puts a “Pause” on FCPA Enforcement - On Monday, President Donald Trump signed an executive order (EO) pausing the enforcement of the Foreign Corrupt Practices Act (FCPA). According to the EO, the pause will...more
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
U.S. Attorney General (AG) Pam Bondi on her first day in office – Feb. 5, 2025 – sent several memos to all employees of the U.S. Department of Justice (DOJ) laying out top priorities. In one memo, the DOJ instructs its...more