WONE Global's guide to United States records these changes under compliance and sanctions. Each statement below has been checked against the source it links to.
Every new FCPA investigation or enforcement action must be authorised by the Assistant Attorney General for the Criminal Division or a more senior Department of Justice official.
Federal; Department of Justice.
US Department of Justice, Office of the Deputy Attorney General · Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA), memorandum of 9 June 2025 ↗ Checked against an official source · Not yet professionally reviewed · checked 18 October 2026
Under Department of Justice guidelines of 9 June 2025, FCPA enforcement prioritises misconduct linked to cartels and transnational criminal organisations, conduct that harms identifiable US companies' ability to compete, threats to national security, and serious misconduct such as large bribes or sophisticated concealment, rather than routine or low-value business courtesies.
Federal; Department of Justice criminal enforcement. The factors are not exhaustive. The guidelines do not bind the SEC's civil enforcement of the FCPA accounting provisions; this was not confirmed on the source.
US Department of Justice, Office of the Deputy Attorney General · Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA), memorandum of 9 June 2025 ↗ Checked against an official source · Not yet professionally reviewed · checked 18 October 2026
This is a summary of the rule as published, not advice on how it applies to you. The WONE Global Partner for this service in United States can advise on that.
