Executive Summary: On June 9, Deputy Attorney General Todd Blanche issued a memorandum to the Department of Justice’s Criminal Division, outlining the Department’s focus for pending and future FCPA actions. A day later, Matthew Galeotti, the Head of the Criminal Division, offered more insight into how this administration will approach FCPA investigations and enforcement actions. Both pronouncements make clear that DOJ will target companies operating abroad who partner with foreign actors, especially those with any connection to cartels or transnational criminal organizations. The Criminal Division may also focus more on individual misconduct, rather than corporate liability—a welcome change for companies.
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