Is the “Pause” Over? DOJ Resumes FCPA Enforcement, Announces Guidelines

Bass Berry & Sims – On June 9, Deputy Attorney General Todd Blanche issued a memorandum entitled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA),” outlining the evaluation criteria and a non-exhaustive list of factors that the Criminal Division should use to determine whether to pursue an FCPA case. The FCPA is the primary law by which the U.S. government seeks to prosecute and penalize bribery of non-U.S. government officials. In conjunction with the issuance of the Memo, the DOJ effectively restarted FCPA prosecution, which was paused according to an Executive Order issued in February 2025.

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