DOJ's New FCPA Enforcement Guidelines: Continuity With A Twist

As directed in a February executive order instructing the Department of Justice (DOJ) to issue guidelines for future Foreign Corrupt Practices Act (FCPA) enforcement, Deputy Attorney General Todd Blanche released updated FCPA enforcement guidelines on June 10, 2025.¹ In the Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)(the Guidelines), DOJ instructs its prosecutors to consider the FCPA in the context of promoting US interests and competitiveness abroad. Specifically, the Guidelines contemplate "limiting undue burdens on American companies that operate abroad" and "targeting enforcement actions against conduct that directly undermines US national interests." The Guidelines signal that FCPA enforcement will serve the Trump administration's "America First" policy mandate, among other priorities. Notably, that same day, head of DOJ's Criminal Division Matthew Galeotti elaborated on the Guidelines, emphasizing the "vindication