Is the “Pause” Over? DOJ Resumes FCPA Enforcement, Announces Guidelines

Bass Berry & Sims – On June 9, Deputy Attorney General Todd Blanche issued a memorandum entitled "Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)," outlining the evaluation criteria and a non-exhaustive list of factors that the Criminal Division should use to determine whether to pursue an FCPA case.