DOJ Ends FCPA Enforcement Pause

June 11, 2025 – On June 9, Deputy Attorney General Todd Blanche issued a memorandum announcing new Foreign Corrupt Practices Act (FCPA) enforcement guidelines. The memorandum responds to President Donald Trump's Feb. 10 Executive Order 14209 (the Executive Order) that temporarily paused new FCPA investigations and called for a reorientation of FCPA enforcement priorities to better align with U.S. economic and national security interests.

Key Takeaways

1. 180-Day Pause Being Lifted but Review Ongoing. Expect FCPA investigations and enforcement actions to resume, but they will focus on new enforcement priorities. The case-by-case review of existing FCPA investigations and enforcement actions is ongoing and will consider these new enforcement priorities.