On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the Guidelines) on “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” by the US Department of Justice (DOJ).

The Guidelines follow President Trump’s February 10, 2025, executive order (the Executive Order), which directed DOJ to “(i) cease initiation of any new FCPA investigations or enforcement actions, unless the Attorney General determines that an individual exception should be made; (ii) review in detail all existing FCPA investigations or enforcement actions and take appropriate action with respect to such matters to restore proper bounds on FCPA enforcement and preserve Presidential foreign policy prerogatives; and (iii) issue updated guidelines or policies as appropriate, to adequately promote the President’s Article II authority to conduct foreign affairs and prioritize American interests, American economic competitiveness with respect to other nations, and the efficient use of Federal law enforcement resources.”

In a June 10, 2025, statement, Deputy Attorney General Blanche noted that the newly announced Guidelines will ensure that enforcement efforts “advance American interests” by “shifting prosecutorial resources to cases that clearly implicate U.S. national security and competitiveness.”

Adding further perspective the same day on the Guidelines, as well as on the Criminal Division’s May 12, 2025, White Collar Enforcement Plan, the Head of DOJ’s Criminal Division, Matthew Galeotti, stated at the American Conference Institute’s Conference on Global Anti-Corruption, Ethics & Compliance that DOJ’s Criminal Division views corporate enforcement as a priority and will continue to “vigorously pursue” white collar investigations.

This Alert summarizes updates to the DOJ’s current FCPA investigation and enforcement approach and offers key considerations and potential action items for companies in light of the Guidelines.

For more details, see our Client Alert.