Blanche’s memo states that the revamped FCPA enforcement strategy focuses on protecting U.S. business interests and national security while scaling back what the administration views as regulatory overreach. The executive order that brought FCPA enforcement to a temporary halt cited concerns that the law was being used in ways that disadvantaged American firms.
The freeze, though controversial, led to a comprehensive internal review at the Justice Department, resulting in a streamlined approach that shuttered nearly half of the department’s open foreign bribery cases and refocused resources on the most geopolitically significant targets. Blanche was blunt in his assessment of the framework, stressing that the DOJ was “ending abusive overreach and closing cases that never should’ve been opened.”
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