DOJ Refocuses on Foreign Bribery with a National Security Lens, Prompting Corporate Compliance Reevaluation


In a significant policy adjustment, the U.S. Department of Justice (DOJ) has shifted its focus within the realm of foreign bribery enforcement, aligning its priorities with national security concerns. This change comes in the wake of the DOJ’s resumption of investigations and prosecutions under the Foreign Corrupt Practices Act (FCPA), following a temporary pause earlier this year. The strategic pivot emphasizes cases that impact national security, such as those involving bribery by foreign companies that disadvantage American competitors, payments to cartels, and activities in sectors critical to national security, such as defense and deep-water ports.

The altered enforcement landscape has prompted businesses, particularly those operating in Latin America and industries deemed vital to U.S. interests, to reassess their compliance strategies. The DOJ’s renewed focus reflects a broader governmental initiative to safeguard U.S. national security interests against the backdrop of global economic competition. Legal professionals and corporate compliance departments will need to navigate this new terrain with an increased emphasis on aligning their operations with the DOJ’s emerging priorities.

For further details on this shift in DOJ policy, the full report is available at Bloomberg Law.