The U.S. Department of Justice (DOJ) is set to revive enforcement of the Foreign Corrupt Practices Act (FCPA), a decades-old law banning bribery of foreign officials by companies operating in the U.S., though with a more focused and less burdensome approach for businesses.
This shift was outlined in a memo from Deputy Attorney General Todd Blanche and further explained by top DOJ official Matthew Galeotti during an anti-corruption conference in New York on Tuesday.
Under the revised strategy, DOJ enforcement will prioritise cases that directly impact U.S. interests, such as those that disadvantage American companies in global competition, involve critical infrastructure, or are connected to cartels or transnational criminal organisations.
“The through line in these guidelines is that they require the vindication of U.S. interests,” said Galeotti, head of the DOJ’s criminal division.
The FCPA has long been a central tool in the federal government’s fight against global corruption.
However, enforcement efforts slowed recently following a review initiated by former President Donald Trump.
The DOJ’s dedicated FCPA unit has also seen a decline in staffing in recent months.
Blanche’s memo signals a move toward more selective enforcement.
All new FCPA investigations are said to now require high-level approval. Some ongoing investigations have already been closed following a comprehensive internal review.
Despite the scaled-back approach, Galeotti emphasised that tackling white-collar and corporate crime remains a critical DOJ priority.
He also highlighted other policy shifts, including a renewed focus on corporate cooperation. Companies that voluntarily disclose misconduct, cooperate with investigations, and implement corrective measures may avoid prosecution.
Additionally, the DOJ is finalising a review of its corporate monitorship policy, where external firms oversee compliance at companies resolving misconduct cases.
According to Galeotti, some monitorships will continue while others will be concluded. “Monitors are meant to be a temporary bridge,” he noted.
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