Clear and Present Danger: How DOJ Trade-Fraud and Anti-Corruption Priorities Show Trade & Customs Risks Are Here to Stay
The U.S. Department of Justice (DOJ) has signaled a renewed and sharpened focus on trade and customs-related misconduct, including tariff evasion. While DOJ’s emphasis on this enforcement area is notable in its own right, this Update highlights how DOJ’s prioritization of trade and customs fraud also brings Foreign Corrupt Practices Act (FCPA) exposure back to the forefront of risks for multinational companies. (more…)
The Freeze Has Thawed: DOJ Issues New Directive to Pursue FCPA Cases that Vindicate U.S. National Interests
On June 10, 2025, the U.S. Department of Justice (DOJ)’s Deputy Attorney General, Todd Blanche, unveiled DOJ’s new “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (FCPA Guidelines). The FCPA Guidelines, directed to the head of the DOJ’s Criminal Division, Matthew R. Galeotti, follows President Donald Trump’s February 10, 2025 executive order (EO) generally pausing FCPA enforcement for 180 days and directing the Attorney General to develop new criteria for new FCPA investigations in that same time period. (The prior EO was analyzed in a Sidley alert available here.)