Category Archives: Transnational Criminal Organizations (TCOs)/Cartels

DOJ Announces First FCPA Enforcement Activity After Months-Long Pause

by Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, and Christopher Cestaro

Left to Right: Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, and Christopher Cestaro (photos courtesy of WilmerHale)

Over the past week, the U.S. Department of Justice (“DOJ”) unsealed its first Foreign Corrupt Practices Act (“FCPA”) enforcement action and issued its first declination since the pause in FCPA enforcement mandated by President Donald Trump’s February 10, 2025 Executive Order (“February Executive Order”)[1] and the subsequent issuance of updated FCPA enforcement guidelines, the Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) (“June Guidelines”).[2]  

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DOJ Announces New Foreign Corrupt Practices Act Enforcement Guidelines

by David B. Anders, John F. Savarese, and Aline R. Flodr

Photos of the authors

Left to right: David B. Anders, John F. Savarese, and Aline R. Flodr (photos courtesy of authors)

On June 9, 2025, Deputy Attorney General Todd Blanche announced the awaited new guidelines for prosecutors investigating and enforcing the Foreign Corrupt Practices Act (“FCPA”).  These enforcement guidelines were issued in response to President Trump’s Executive Order titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security,” which directed DOJ to “pause” certain FCPA investigations while reassessing enforcement priorities and to issue new FCPA enforcement guidelines within 180 days.  The stated aim of the new policy is to reduce undue burdens on American companies operating abroad and to focus on activities that undermine U.S. national interests.  The memorandum announcing the guidelines directs prosecutors to consider the following non-exhaustive factors and confirms that these new guidelines shall govern all current and future FCPA investigations and enforcement actions:

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