What’s in DOJ’s New Guidelines for FCPA Enforcement?

Описание: New DOJ Guidelines on FCPA Enforcement: What Companies Need to Know

The U.S. Department of Justice has released new enforcement guidelines for the Foreign Corrupt Practices Act (FCPA), introducing a more focused approach to investigations and compliance expectations. In this interview, John Cunningham, who leads the corporate compliance team at Dickinson Wright, breaks down what’s changed and how companies should respond.

Cunningham explains how the DOJ’s updated guidance differs from previous joint DOJ–SEC frameworks, highlighting a shift toward targeted priorities, including combating cartel influence in global supply chains, addressing money laundering risks, and strengthening corporate compliance measures.

The discussion also explores how multinational companies should adjust their due diligence, internal controls, and third-party oversight—especially when operating in higher-risk regions. With increased attention on cartel activity and financial crimes tied to bribery, organizations must reassess how they monitor payments, manage supply chain partners, and handle potential violations.

If your company operates internationally or relies on complex supply chains, this conversation offers valuable insight into risk mitigation, compliance strategies, and when to consider voluntary self-reporting to regulators.

Topics covered in this video:

Key changes in DOJ FCPA enforcement guidelines

How the new priorities differ from previous DOJ/SEC guidance

The connection between cartels, bribery, and money laundering

Why enhanced due diligence in supply chains is critical

Compliance steps companies should take right now

When businesses should consider self-reporting potential violations

About the Guest:
John Cunningham leads the Corporate Compliance Team at Dickinson Wright and is the author of Five Essential Elements of Corporate Compliance: A Global Template.

#FCPA #CorporateCompliance #DOJ #SupplyChainRisk #AntiCorruption #Compliance #RiskManagement