Trump Administration’s FCPA Investigations and Enforcement Guidelines
On June 9, Deputy Attorney General Todd Blanche released a much-anticipated update to the Trump administration’s plans for enforcement of the Foreign Corrupt Practices Act (FCPA). The Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) demonstrate that FCPA enforcement will continue under the Trump administration, but the Department of Justice’s (DOJ) focus will be much different than under prior administrations. Further, the DOJ’s enforcement standards will be different, with guaranteed declination of enforcement for those companies that “voluntarily self-report, cooperate, and remediate,” as established in the revised Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and articulated by Head of the DOJ’s Criminal Division Matthew Galeotti in his June 10 remarks . Background The guidelines follow a series of announcements by the administration in February regarding the FCPA. On February...