The guidelines confirm that FCPA enforcement will continue but provide opportunities for foreign authorities to lead where US interests are not significantly impacted.

By Clare Nida, Pamela Reddy, Nathan H. Seltzer, Annie Birch, and Emma Bunting

On 9 June 2025, US Department of Justice (DOJ) Deputy Attorney General Todd Blanche issued a memorandum outlining guidelines (the Guidelines) for investigations and enforcement actions brought by DOJ under the Foreign Corrupt Practices Act (FCPA). This follows on from…