DOJ Issues Transformative FCPA Guidelines Prioritizing U.S. National Interests

On June 9, 2025, the Department of Justice under Deputy Attorney General Todd Blanche released updated Foreign Corrupt Practices Act (FCPA) guidelines, effectively ending the four-month enforcement pause instituted by a Trump administration executive order. The new guidelines fundamentally reshape anti-corruption enforcement by: (1) prioritizing investigations directly tied to U.S. national security and economic interests, (2) focusing on individual criminal misconduct rather than broad corporate liability, and (3) requiring high-level DOJ authorization for new investigations. Prosecutors are now instructed to target cases involving cartels, transnational criminal organizations, and serious misconduct that demonstrably threatens U.S. interests.