DOJ Announces First FCPA Enforcement Activity After Months-Long Pause

Over the past week, the U.S. Department of Justice ("DOJ") unsealed its first Foreign Corrupt Practices Act ("FCPA") enforcement action and issued its first declination since the pause in FCPA enforcement mandated by President Donald Trump's February 10, 2025 Executive Order ("February Executive Order")¹ and the subsequent issuance of updated FCPA enforcement guidelines, the Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) ("June Guidelines").²

As we noted in our recent client alert,³ the June Guidelines directed FCPA investigations and enforcement actions to focus on a non-exhaustive list of factors that align with the administration's stated priorities: eliminating cartels and transnational criminal organizations (TCOs); safeguarding U.S. business competitiveness; advancing U.S. national security; and prioritizing investigations of serious misconduct as opposed to routine business practices in other nations. The conduct