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Episode 372 -- DOJ Applies False Claims Act to Tariff and Trade Violations
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
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
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
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
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
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
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
On June 9, 2025, the U.S. Department of Justice (DOJ) released a memorandum establishing long-awaited guidance for the investigation and enforcement of the Foreign Corrupt Practices Act (FCPA). The guidance was a direct...more
Shortly after taking office President Trump signed an executive order titled, “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.” Among other things, President Trump...more
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
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
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
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
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
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
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 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
In February 2025, President Trump signed an executive order directing the U.S. Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) and to update its guidelines for enforcing the FCPA....more
On February 10, 2025, President Donald Trump issued an executive order pausing new Foreign Corrupt Practices Act (FCPA) investigations for 180 days (the EO). The EO directs the US Department of Justice (DOJ) to review...more
Key Points - - The U.S. Department of Justice (DOJ) will resume investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA), prioritizing, in part, FCPA actions involving cartels and transnational...more
On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the DAG memorandum) updating the Department of Justice’s (DOJ) enforcement guidelines for the Foreign Corrupt Practices Act (FCPA) in accordance with...more
On June 9, 2025, the Deputy Attorney General issued a Memorandum detailing the administration’s new FCPA guidelines for all current and future investigations and enforcement actions. According to the Head of DOJ’s Criminal...more
On June 9, Deputy Attorney General Todd Blanche issued a memorandum (the Memorandum) outlining revised guidelines for investigation and enforcement of the Foreign Corrupt Practices Act (FCPA). The U.S. Department of Justice...more