The long-anticipated guidance released by the U.S. Department of Justice (DOJ) on June 9, 2025 (the Guidelines) reorients Foreign Corrupt Practices Act (FCPA) enforcement, shifting the DOJ’s focus to more centrally controlled, national-interest-driven anti-corruption misconduct. Below is an overview of the background and salient shifts driven by the Guidelines.

Given the recent changes the Trump Administration has made at the Department of Justice (DOJ),many people have wondered when a formal change to the DOJ’s white-collar prosecution policies, particularly the corporate self-disclosure policy, might come. During remarks at a Financial Crimes Conference on May 12, Matthew Galeotti, the new Head of the DOJ’s Criminal Division, announced some of the changes to the DOJ’s policies, starting with the new commitment to be less “heavy-handed with the stick, and [less] stingy with the carrot.”