DOJ Resumes Foreign Bribery Enforcement Prioritizing US Interests

The U.S. Department of Justice (DOJ) has ended its six-month pause on enforcing the Foreign Corrupt Practices Act (FCPA), resuming investigations and prosecutions with a renewed focus on protecting U.S. businesses and national security interests, following an executive order by President Donald Trump. Deputy Attorney General Todd Blanche issued new guidelines prioritizing cases that involve foreign bribery which undermines the competitiveness of U.S. firms, particularly in critical sectors such as defense, intelligence, energy, and critical infrastructure, as well as cases tied to criminal organizations and cartels. The DOJ plans to limit burdens on American companies by focusing enforcement on misconduct that directly threatens U.S. interests, requiring approval from top officials for new investigations, and closing certain legacy cases initiated under the previous administration. DOJ Criminal Division Chief Matthew Galeotti emphasized the shift toward vindicating U.S. interests and indicated that companies cooperating and remediating misconduct may avoid prosecution. The enforcement overhaul reflects President Trump's directive to review and recalibrate FCPA enforcement, aiming to protect American businesses from unfair competition caused by foreign bribery. This approach also includes reassessing corporate monitorships as part of the broader strategy against white-collar crime.