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Foreign Corrupt Practices Act (FCPA) Trump Administration Bribery

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

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

Cooley LLP

DOJ Resumes Foreign Bribery Investigations, Focusing on ‘Vindication of US Interests’

Cooley LLP on

On June 9, 2025, the Department of Justice (DOJ) issued new guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (FCPA), following a four-month pause of new FCPA investigations per President...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

K&L Gates LLP

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

K&L Gates LLP on

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

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

Mayer Brown

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

Mayer Brown on

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

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

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

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

King & Spalding

A New Era of FCPA Enforcement

King & Spalding on

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

Wilson Sonsini Goodrich & Rosati

DOJ to Use FCPA as a Tool for Advancing White House Priorities and American Competitiveness

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

McDermott Will & Emery

DOJ Revives FCPA Enforcement With Narrower Scope

McDermott Will & Emery on

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

Skadden, Arps, Slate, Meagher & Flom LLP

Deputy Attorney General Issues FCPA Guidelines Resuming Limited Enforcement

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

Ballard Spahr LLP

Focused FCPA Enforcement: Emphasizing Security and Strategic Interests

Ballard Spahr LLP on

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

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

Lowenstein Sandler LLP

The End of 180 Days of Uncertainty? DOJ Closes Current FCPA Investigations, Issues New Guidelines for FCPA Enforcement

Lowenstein Sandler LLP on

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

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

Ropes & Gray LLP

DOJ’s New FCPA Playbook: “Time To Get To Work”

Ropes & Gray LLP on

On June 9, 2025, the U.S. Department of Justice (“DOJ” or the “Department”) issued the highly anticipated guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (“FCPA”) (“FCPA Guidelines”),...more

Cozen O'Connor

DOJ Restarts Enforcement of Foreign Corrupt Practices Act, Focusing on U.S. Interests

Cozen O'Connor on

On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum titled "Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)." The memo follows a four-month review triggered by...more

DLA Piper

DOJ’s New FCPA Guidelines: The Next Chapter in US Foreign Corruption Enforcement

DLA Piper on

The Department of Justice (DOJ) has released long-awaited guidance (FCPA Guidelines) regarding its approach to enforcement of the Foreign Corrupt Practices Act (FCPA) following the Executive Order (EO) pausing FCPA...more

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