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FCPA Un-Paused: DOJ Announces New Guidelines for FCPA Enforcement

On June 9, 2025, in a memorandum entitled Guidelines for Investigations and Enforcement of the FCPA(the “Guidelines”), the Department of Justice (DOJ) signaled that Foreign Corrupt Practices Act (FCPA) investigations and...more

The Future of Anti-Corruption Enforcement: Potentially Increasing State and Non-US Prosecutions as an Alternative to the FCPA

On February 10, 2025, President Donald Trump signed an executive order instructing the United States Department of Justice (“DOJ”) to pause enforcement of the Foreign Corrupt Practices Act (“FCPA”) for a period of 180 days....more

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