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ARTICLE · 16 JUNE 2025

Focused FCPA Enforcement: Emphasizing Security And Strategic Interests

Ballard Spahr LLP
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On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the DAG memorandum)...

United StatesCriminal Law
Henry E. Hockeimer
Henry E. Hockeimer
Emilia McKee Vassallo
Emilia McKee Vassallo
Kelly A. Lenahan-Pfahler
Kelly A. Lenahan-Pfahler
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On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the DAG memorandum) updating the Department of Justice's (DOJ) enforcement guidelines for the Foreign Corrupt Practices Act (FCPA) in accordance with Executive Order 14209 (Order) that President Trump signed on February 10, 2025. The Order temporarily suspended new FCPA investigations to reduce regulatory burdens on American businesses, with specific exceptions allowed by the Attorney General. The DAG memorandum articulates the DOJ's guidelines pursuant to the Order, marking a significant shift in FCPA enforcement that emphasizes both national security and the protection of U.S. business interests abroad.

Strategic Enforcement Priorities

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