DOJ Issues New FCPA Enforcement Guidelines

New factors for investigating and enforcing the Foreign Corrupt Practices Act were recently released by the head of the Criminal Division of the U.S. Department of Justice (DOJ) in "Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)," June 9, 2025. The memorandum aims to ensure that FCPA enforcement is carried out in accordance with President Trump's Executive Order, "Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security," by (1) limiting undue burdens on American companies that operate abroad and (2) targeting enforcement actions against conduct that directly undermines U.S. national interests. See Exec. Order No. 14209, 90 Fed. Reg. 9587 (Feb. 10, 2025).