The U.S. Justice Department is relaunching its enforcement of the Foreign Corrupt Practices Act (FCPA), but this time with less muscle and more national focus. Gone are the sweeping international probes of the past—this new chapter is narrower, leaner, and unapologetically aimed at defending U.S. business interests abroad.
In a policy shift outlined by Deputy Attorney General Todd Blanche, the DOJ will now target foreign bribery cases that directly impact America’s economic competitiveness, strategic infrastructure, or intersect with cartels and global crime networks. The message? Unless it tangibly harms U.S. interests, the feds might just look the other way.
Matthew Galeotti, head of the DOJ’s criminal division, spelled it out during an anti-corruption forum in New York: “The through line in these guidelines is that they require the vindication of U.S. interests.”
This reboot follows a quiet retreat from full-throttle FCPA enforcement in recent years, spurred by a Trump-era review that questioned the utility of targeting U.S. companies for foreign misdeeds. The once-robust enforcement unit has since thinned out, but Blanche’s memo signals a revival—albeit with tighter controls. All new investigations must now get the green light from senior leadership.
Notably, this isn’t just a shift in scope—it’s a change in tone. Companies that come clean, cooperate fully, and implement internal fixes may escape prosecution altogether. The Department is also rethinking its corporate monitor policies, ending some and keeping others, with Galeotti calling them “a temporary bridge” rather than a permanent fixture.
It’s a recalibration, not a retreat. But the days of broad anti-bribery crusades appear to be over. The DOJ’s new mantra: Clean up your mess, help us when we ask, and if you’re not hurting America—we might just let it slide.
