News & Analysis as of

Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) National Security

Dickinson Wright

QuickHits: DOJ’s FCPA Shift and Impacts on U.S.-China Operations

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Welcome to QuickHits. This brief newsletter covers recent cases, legal developments, and key questions affecting the evolving U.S.-China relationship and related business and legal environments. It’s produced by attorneys...more

Foley & Lardner LLP

The Trump Administration 2.0’s FCPA Enforcement Strategy: What You Need to Know

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On June 9, 2025, the U.S. Department of Justice (DOJ) released significant new guidance outlining how it will pursue cases under the Foreign Corrupt Practices Act (FCPA), marking a reorientation in U.S. anti-bribery...more

Woods Rogers

DOJ Narrows Foreign Corrupt Practices Act Enforcement Focus

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The Department of Justice (DOJ) is narrowing its focus on Foreign Corrupt Practices Act (FCPA) enforcement, prioritizing national security, U.S. competitiveness, and a crackdown on cartels. This is a critical development for...more

Nossaman LLP

DOJ Issues New FCPA Enforcement Guidelines

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New factors for investigating and enforcing the Foreign Corrupt Practices Act were recently released by head of the Criminal Division of the U.S. Department of Justice (DOJ) in, “Guidelines for Investigations and Enforcement...more

Baker Donelson

Update: DOJ Issues Guidelines for Protectionist FCPA Enforcement

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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

Vinson & Elkins LLP

DOJ Resumes FCPA Enforcement with a New “America First” Focus on Energy and Other Vital National Interests — Creating...

Vinson & Elkins LLP on

On June 9, 2025, Deputy Attorney General Todd Blanche announced that the U.S. Department of Justice (“DOJ” or the “Department”) will resume investigating and prosecuting violations of the U.S. Foreign Corrupt Practices Act...more

Jenner & Block

Client Alert: Back in Action: The Trump Administration Lifts “Pause” in Foreign Corrupt Practices Act Enforcement

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Approximately four months after President Trump imposed a pause on new Foreign Corrupt Practice Act (FCPA) investigations and enforcement actions, the US Department of Justice (DOJ) has issued new guidelines lifting that...more

Jones Day

DOJ Resumes FCPA Enforcement Under New Guidelines Prioritizing the Protection of American Interests

Jones Day on

In response to President Trump's February 10, 2025, Executive Order pausing DOJ FCPA enforcement (the "Executive Order"), on June 9, 2025, the DOJ issued new guidelines (the "Guidelines"), which prioritize the enforcement of...more

Herbert Smith Freehills Kramer

DOJ resumes FCPA enforcement with new guidelines

On June 10, 2025, the head of the Criminal Division of the Department of Justice (DOJ), Matthew Galeotti, declared in a speech that the DOJ would resume enforcing the Foreign Corrupt Practices Act (FCPA). This announcement...more

Porter Hedges LLP

DOJ Issues New Guidelines Narrowing FCPA Enforcement Scope

Porter Hedges LLP on

On June 9, 2025, the Department of Justice (DOJ) released updated guidelines governing the enforcement of the Foreign Corrupt Practices Act (FCPA), signaling a more focused and strategic approach to foreign bribery cases. The...more

Troutman Pepper Locke

Trump Administration's FCPA Investigations and Enforcement Guidelines

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On June 9, Deputy Attorney General Todd Blanche released a much-anticipated update to the Trump administration’s plans for enforcement of the Foreign Corrupt Practices Act (FCPA)....more

Bradley Arant Boult Cummings LLP

DOJ Issues FCPA Investigations and Enforcement Guidelines

On February 10, 2025, President Donald J. Trump signed Executive Order 14209, titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.” That order marked a major shift in...more

A&O Shearman

DOJ releases new FCPA enforcement guidelines

A&O Shearman on

On June 9, 2025, the U.S. Department of Justice (DOJ) released new guidelines for investigating and enforcing the Foreign Corrupt Practices Act (FCPA), in response to President Trump's February 10, 2025 Executive Order 14209...more

K&L Gates LLP

The FCPA is Back—What Companies Need to Know About DOJ's New America-First Enforcement Priorities

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On 9 June 2025, Deputy Attorney General Todd Blanche released a memo (the Blanche Memo) detailing the long-awaited enforcement guidelines on how the Department of Justice (DOJ) under Attorney General Pam Bondi will enforce...more

Alston & Bird

FCPA Pause, We Hardly Knew Ye: The DOJ Issues New FCPA Enforcement Guidance

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Our White Collar, Government & Internal Investigations Team analyzes new guidance from the Department of Justice that signals continued—and potentially heightened—enforcement of the Foreign Corrupt Practices Act....more

Arnall Golden Gregory LLP

DOJ’s New FCPA Guidelines Shifts Enforcement Priorities to Focus on National Security and Economic Competitiveness

On June 9, 2025, the U.S. Department of Justice released a memorandum titled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA),” formalizing an anticipated realignment of federal...more

Cadwalader, Wickersham & Taft LLP

The Pause is Over—the FCPA Lives On

On June 9, 2025, the U.S. Department of Justice (DOJ) announced the resumption of Foreign Corrupt Practices Act (FCPA) enforcement, ending the enforcement pause initiated by Executive Order 14209. In doing so, Deputy Attorney...more

Venable LLP

FCPA Enforcement Resumes with New Guidelines Focused on Strategic U.S. Interests

Venable LLP on

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

Bass, Berry & Sims PLC

Is the “Pause” Over? DOJ Resumes FCPA Enforcement, Announces Guidelines

Bass, Berry & Sims PLC on

On June 9, Deputy Attorney General Todd Blanche issued a memorandum entitled Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (the Memo) addressed to the head of the Criminal Division of the...more

Sheppard Mullin Richter & Hampton LLP

DOJ Releases Promised Guidelines for Investigation and Enforcement Under the FCPA

On Monday June 9, 2025, the Deputy Attorney General Todd Blanche released “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act.” This much anticipated update directly responds to Executive Order...more

BakerHostetler

FCPA Enforcement Is Back with a New Enhanced Focus on Protecting US Business Abroad, National Security, Individuals and (of...

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U.S. Department of Justice (DOJ) Deputy Attorney General Todd Blanche issued a memorandum on June 9 (the Memo), announcing DOJ will resume enforcement of the Foreign Corrupt Practices Act (FCPA) after its brief hiatus....more

Hogan Lovells

FCPA reloaded: The DOJ “unpauses” enforcement – But is it a new level?

Hogan Lovells on

On June 9, 2025, Deputy Attorney General Todd Blanche issued revised enforcement guidelines for the Foreign Corrupt Practices Act (FCPA), officially ending the FCPA enforcement pause that Executive Order 14209 (EO) instituted...more

Husch Blackwell LLP

DOJ Poised to Reboot FCPA Investigations and Enforcement

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Issued on February 10, 2025, Executive Order 14209 (“Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security”) called on the Department of Justice (DOJ) to “review guidelines and...more

Paul Hastings LLP

New DOJ FCPA Guidelines Target Cases Linked to US Strategic Interests

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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

King & Spalding

A New Era of FCPA Enforcement

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On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the “Blanche Memorandum”) detailing new guidelines for the Department of Justice’s approach to investigating and enforcing the Foreign Corrupt...more

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