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.
Need to refresh your FCPA training? Let’s talk.