Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)

This memorandum outlines new Justice Department guidelines for investigating and enforcing the Foreign Corrupt Practices Act (FCPA) following Executive Order 14209. It directs prosecutors to pause new cases except in certain circumstances, prioritize threats to U.S. national security, and target bribery linked to cartels, transnational criminal organizations, or harm to U.S. businesses. The memo emphasizes limiting unnecessary burdens on American companies, focusing on serious misconduct rather than routine practices, and considering foreign enforcement capabilities. These changes reflect a shift toward aligning anti-corruption enforcement with broader economic and security priorities.