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Foreign Corrupt Practices Act (FCPA) Criminal Prosecution Executive Orders

Latham & Watkins LLP

DOJ Focuses FCPA Enforcement With New Guidelines

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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

Jones Day

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

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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

Vedder Price

DOJ Issues New FCPA Enforcement Guidelines

Vedder Price on

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

Katten Muchin Rosenman LLP

Updated FCPA Guidance

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

Mayer Brown

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

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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

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

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

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

Akin Gump Strauss Hauer & Feld LLP

DOJ Hits Play: The End of the FCPA “Pause” and Return to Enforcement

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

Fenwick & West LLP

DOJ Unpauses FCPA Enforcement with New Limits

Fenwick & West LLP on

On February 10, 2025, the president signed an executive order that paused investigation and enforcement of the FCPA for a period of 180 days, required the DOJ to review any existing FCPA investigation or prosecution, and to...more

Baker Botts L.L.P.

Back from the Dead? Takeaways from US DOJ’s New Guidelines for FCPA Investigations and Enforcement

Baker Botts L.L.P. on

On June 9, 2025, the Deputy Attorney General of the United States Department of Justice issued “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (the “Memorandum”). The Memorandum...more

Akin Gump Strauss Hauer & Feld LLP

The European Response to DOJ’s FCPA Enforcement “Pause”

On March 20, 2025, the United Kingdom, France and Switzerland jointly announced the formation of a new International Anti-Corruption Prosecutorial Taskforce (the “Task Force”) aimed at strengthening cross-border collaboration...more

Baker Donelson

DOJ Dismisses FCPA Charges Against Former Cognizant Executives Following New Policy

Baker Donelson on

On April 2, 2025, the U.S. Department of Justice (DOJ) moved to dismiss the Foreign Corrupt Practices Act (FCPA) case against former Cognizant Technology Solutions Corp. executives Gordon Coburn and Steven Schwartz, United...more

A&O Shearman

Criminal Case Against Former Executives Of Technology Company Dismissed

A&O Shearman on

On April 2, 2025, the Department of Justice moved to dismiss with prejudice its Foreign Corrupt Practices Act (“FCPA”) case against two former executives of a technology solutions company (“Company”). The executives were...more

A&O Shearman

US Attorney For The District of New Jersey Reverses Course And Requests Adjournment For Foreign Bribery Case Against Tech...

A&O Shearman on

On March 4, 2025, one day before a trial against former tech executives for alleged foreign bribery charges was set to commence, the United States Attorney for the District of New Jersey requested 180-day adjournment. The...more

Womble Bond Dickinson

Compliance Still Matters: The Future of FCPA Enforcement

Womble Bond Dickinson on

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

Troutman Pepper Locke

Key Considerations After DOJ Announces Shifting Enforcement Priorities

Troutman Pepper Locke on

On February 5, U.S. Attorney General (AG) Pam Bondi issued 14 memoranda to Department of Justice (DOJ) employees framing the DOJ's current policies and enforcement priorities. These shifting enforcement priorities are aligned...more

Holland & Knight LLP

President Trump Issues Executive Order to Halt FCPA Enforcement

Holland & Knight LLP on

President Donald Trump signed an executive order (EO) pausing all future investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA) for at least 180 days, along with directing the U.S. attorney...more

Vedder Price

Changed Focus of FCPA Actions Under Trump Executive Order

Vedder Price on

On February 5, 2025, newly appointed U.S. Attorney General Pam Bondi issued a memorandum titled “Total Elimination of Cartels and Transnational Criminal Organizations” (the February 5 Memorandum), which outlined a broad...more

K&L Gates LLP

President Trump Orders FCPA Freeze; DOJ Announces Major Policy Realignment De-Emphasizing Corporate Investigations and Enforcement

K&L Gates LLP on

The much-heralded end to prosecutions brought pursuant to the Foreign Corrupt Practices Act (FCPA) never materialized during the first Donald Trump administration, but Trump 2.0 has the potential to bring major change to the...more

Ballard Spahr LLP

Attorney General Bondi Overhauls Justice Priorities

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The new administration has signaled that the Department of Justice (“DOJ”) will significantly shift its approach to criminal corporate enforcement. Specifically, on February 5, 2025, newly-confirmed United States Attorney...more

Vinson & Elkins LLP

Future of FCPA Enforcement Uncertain (For Now) as New Administration Revamps the Law Enforcement Toolkit

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Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more

Cozen O'Connor

U.S. Dials Back Implementation of Foreign Corrupt Practices Act

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On February 10, 2025, President Trump signed an executive order instructing the Department of Justice (DOJ) and Attorney General (AG) Pamela Bondi to “cease initiation of any new [Foreign Corrupt Practices Act (FCPA) (15...more

White & Case LLP

FCPA Freeze and Refocus: Is Enforcement Becoming a Tool to Promote U.S. Economic, Foreign Policy and National Security Interests?

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On February 10, 2025, President Trump signed an executive order instructing the Attorney General of the United States to pause enforcement of the Foreign Corrupt Practices Act ("FCPA") and to issue updated guidelines for...more

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