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


