New U.S. DOJ Antitrust Leadership Signals More Criminal Prosecutions and Longer Prison Sentences
Two weeks after a leadership shakeup in the U.S. Department of Justice (DOJ) Antitrust Division, Acting Deputy Assistant Attorney General for Criminal Enforcement Daniel W. Glad stressed in his first public remarks that the Division’s criminal enforcement program will remain highly active and that individuals involved in criminal antitrust offenses should continue to expect lengthy prison sentences. To drive home this message, Glad highlighted the fact that the Antitrust Division opened nearly 100 criminal investigations in FY 2025 and secured prison sentences that reflected more than a 1,200% increase in prison days imposed year-over-year. He cautioned that individuals who commit criminal antitrust offenses should “be aware that what’s on the line isn’t just a fine — it’s their … liberty.”
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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.)
