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Breaking Down DOJ’s New FCPA Enforcement Guidelines

On June 9, the DOJ released its Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act, ending a months-long pause on FCPA enforcement and outlining DOJ’s go-forward criteria for evaluating whether to bring FCPA actions. Here’s a breakdown of the key themes in the guidelines.

6 minute read July 01, 2025 at 12:03 AM
By
Mark Mendelsohn and Benjamin Klein
Breaking Down DOJ’s New FCPA Enforcement Guidelines

On June 9, the U.S. Department of Justice (DOJ) released its Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) (the guidelines) ending a months-long pause on FCPA enforcement and outlining DOJ’s go-forward criteria for evaluating whether to bring FCPA actions.

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