DOJ Updates FCPA Guidance: What You Need to Know

On June 9, 2025, the U.S. Department of Justice (DOJ) released new guidance on how it will enforce the Foreign Corrupt Practices Act (FCPA). The update signals a more focused and strategic approach to fighting foreign bribery—and it has key implications for compliance teams.

What’s Changed?

  • Narrower Focus:
    New cases will only move forward if they affect U.S. interests—like national security, American businesses, or critical infrastructure. The DOJ wants its efforts to have real impact.
  • Focus on Individuals
    Expect enforcement to target serious misconduct by individuals—especially large bribes, cover-ups, or links to organized crime. Minor, routine issues are less likely to trigger investigations.
  • Faster Investigations
    Prosecutors are being told to move quickly and focus on the biggest risks. Long, drawn-out probes are out. Efficiency and proportionality are in.

What It Means for Compliance

Now is the time to:

  • Update your risk assessments to focus on high-stakes areas.
  • Prioritize serious misconduct over routine issues.
  • Strengthen reporting and response systems—self-reporting still matters.
  • Review training and policies to ensure your team understands the new expectations.

At Ethiciti, we make anti-corruption training simple, effective, and globally scalable. Our modern, flexible courses help teams spot red flags early and respond the right way.


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