FCPA Pause Ends with U.S. DOJ’s New “America First” Enforcement Strategy

On June 9, 2025, the U.S. Department of Justice published the Criminal Division’s updated Guidelines for Investigations and Enforcement for the Foreign Corrupt Practices Act, announcing an early end to the anticipated 180-day pause to FCPA enforcement ordered by the Trump Administration on February 10, 2025. This pause brought into question the fate of the FCPA, leaving many wondering about the implications—that is, until the DOJ revealed its new White-Collar Enforcement Plan a few weeks ago, which listed bribery as a continued top priority area. 

With the new FCPA Enforcement Guidelines in place, Matthew R. Galeotti, Head of the DOJ’s Criminal Division, confirmed that the DOJ “will enforce the FCPA—firmly but fairly—by bringing enforcement actions against conduct that directly undermines U.S. national interests without losing sight of the burdens on American companies that operate globally.” Unsurprisingly, these Guidelines reflect many of the principles set forth in the White-Collar Enforcement Plan, including the emphasis on U.S. interests, as well as “focus, fairness, and efficiency.” It remains to be seen precisely what that will mean for FCPA enforcement in the near future. 

Please see our client publication for further details.