FCPA Guidelines for Investigations and Enforcement
Summary
The DOJ Antitrust Division has updated its Foreign Corrupt Practices Act (FCPA) Guidelines for Investigations and Enforcement. These updated guidelines, effective June 9, 2025, provide clarity on the DOJ's approach to FCPA enforcement and investigations.
What changed
The Department of Justice's Antitrust Division has issued updated Foreign Corrupt Practices Act (FCPA) Guidelines for Investigations and Enforcement, effective June 9, 2025. The document, linked via a PDF, provides detailed information on the DOJ's enforcement priorities, investigative procedures, and factors considered in FCPA cases. This update aims to offer greater transparency and guidance to companies operating internationally regarding anti-corruption compliance.
Companies and individuals subject to the FCPA should review these updated guidelines to ensure their compliance programs align with the DOJ's current enforcement stance. While the guidelines are non-binding, adherence to their principles is crucial for mitigating legal risks and potential penalties. The update emphasizes the DOJ's commitment to prosecuting FCPA violations and encourages proactive compliance measures.
What to do next
- Review updated FCPA Guidelines for Investigations and Enforcement
- Assess current FCPA compliance programs against updated guidance
- Consult legal counsel on any identified compliance gaps
Source document (simplified)
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FCPA Guidelines
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| Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) (June 9, 2025) |
Updated June 10, 2025
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