A strategic turn in U.S. Anti-Bribery Law: the Department of Justice releases new Foreign Corrupt Practices Act Guideline

Posted on 03.07.2025

Following President Trump’s executive order pausing enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days, the U.S. Department of Justice (DOJ) released the awaited guidelines on 9 June 2025 to govern its application.

These guidelines shift the DOJ’s focus toward protecting U.S. national and economic interests, prioritising enforcement against cartels and and practices detrimental to American competitiveness. 

While enforcement priorities are shifting toward high-impact cases and despite assurances that the DOJ will not target companies based on nationality, for non-US companies may be well advised to maintain strong compliance frameworks to avoid exposure under evolving scrutiny.

For further information, please contact Marta Paci, Junior Legal Counsel.