Unpacking the Department of Justice’s New FCPA Enforcement Priorities
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 ...