Compliance Stuff

New guidelines governing Foreign Corrupt Practices Act (FCPA) investigations and enforcement e ffectively signal the official end of the proclaimed FCPA enforcement pause announced by President Trump earlier in the year, while marking the start of many new priority areas of FCPA enforcement. The  guidelines , issued June 9 by Deputy Attorney General (DAG) Todd Blanche, follow the direction of the Trump administration’s laser sharp focus on the “total elimination” of cartels and Transnational Criminal Organizations (TCOs) and build upon the priorities spelled out in Attorney General Pamela Bondi’s memorandum issued in February. That memo, in part, directed FCPA Unit prosecutors in the DOJ’s Criminal Division to prioritize investigations relating to foreign bribery connected to the criminal operations of cartels and TCOs and to shift focus away from cases that don’t have such a connection. Separately,  Executive Order 14209  directed the DOJ to cease initiation of any new ...

With 2025 underway, the ArentFox Schiff White Collar team highlights the  US  Department of Justice’s ( DOJ ) new enforcement priorities and two cases pending before the  US  Supreme Court that could have sweeping implications for future white-collar fraud cases.   Within hours of her US Senate confirmation on February 5, Attorney General Pam Bondi issued 14 memoranda to all DOJ employees, shifting the DOJ’s focus toward national security priorities and reallocating investigative resources and personnel. These memoranda largely implement directives set forth in executive orders issued in the first days of the Trump Administration. The DOJ’s new enforcement priorities include illegal immigration, human smuggling, and transnational crime organizations (TCOs), gangs, and cartels . In support of these priorities, the DOJ will prioritize Foreign Corrupt Practices Act (FCPA) and Foreign Agent Registration Act (FARA) actions with connections to TCOs, gangs, and c...