Tag Archives: Aline R. Flodr

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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White-Collar and Regulatory Enforcement: What Mattered in 2024 and What to Expect in 2025

by David B. Anders, Sarah K. Eddy, Kevin S. Schwartz, Randall W. Jackson, Ralph M. Levene, Michael W. Holt, Aline R. Flodr, and John F. Savarese

Photos of authors

Top left to right: David B. Anders, Sarah K. Eddy, Kevin S. Schwartz, Randall W. Jackson.
Bottom left to right: Ralph M. Levene, Michael W. Holt, Aline R. Flodr, John F. Savarese. (Photos courtesy of authors)

As we write this memorandum, President Trump’s second administration is forming in Washington, with new leadership teams being appointed at DOJ, the SEC and across other regulatory and law-enforcement agencies.  In 2017, when President Trump first took office, we avoided predicting what the administration’s significant white-collar and regulatory enforcement priorities and policies might be in the absence of noteworthy signals from President Trump or his nominees and in light of the then slow pace of leadership confirmations. Eight years later, however, the lessons from President Trump’s first administration, as well as the track record and statements from his recent nominees and closest advisors, offer some insights into the new administration’s likely enforcement priorities.  Given that, we have some thoughts on what to expect from President Trump’s second term:

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