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    Jan. 14, 2026

2025 in Review: DOJ Perspectives on How the Blanche Memo Restarted FCPA Enforcement

Two years shy of its 50th birthday, the FCPA’s continued existence was called into doubt when President Donald Trump’s executive order suspended the law’s enforcement for 180 days starting in February 2025. Then, in a surprise move in June, Deputy AG Todd Blanche issued a memorandum providing guidelines for FCPA cases (Blanche Memo), restarting the FCPA pipeline sooner than expected. This article, the second in a series reviewing 2025 developments, synthesizes comments made by DOJ leaders at the American Conference Institute’s 42nd Annual Conference on FCPA about the eventful year and what lies ahead for enforcement. The first article examined the DOJ’s declaration on continuing white-collar enforcement the “right way.” See our two-part series on the Blanche Memo’s take on corporate responsibility: “Individuals Versus Corporations” (Sep. 10, 2025), and “Collateral Consequences and Global Norms” (Oct. 8, 2025).

How Companies With Ties to Japan Are Impacted by 2025’s Whistleblower Updates

A series of consequential U.S. legal and policy developments, along with Japan’s newly enacted amendments to its Whistleblower Protection Act, have meaningfully shifted the compliance landscape since the Anti-Corruption Report’s prior coverage in July 2024. In this follow-up guest article, Lowenstein Sandler partner Robert Johnston and associate Kei Komuro explain how the updates move both the U.S. and Japan toward more enforceable protections, sharper anti-retaliation rules and closer regulatory oversight, as well as the implications for companies with ties to both countries. See “Whistleblower Protection and Compliance: A Comparative Study of the United States and Japan” (Jul. 31, 2024).

The Impact on Latin America of Designating Cartels As FTOs

On the first day of his second term, President Donald Trump signed an executive order authorizing the Secretary of State to designate international narcotics cartels and other transnational criminal organizations (TCOs) as foreign terrorist organizations (FTOs). Thirteen TCOs, all based in Latin America or Haiti, have since been designated as FTOs. A company dealing with an FTO can find itself facing criminal and civil consequences much more severe than those for other types of criminal activity. During a panel discussion at the New York City Bar’s International White Collar Crime Symposium 2025, experts discussed the import of these designations and debated their virtues and harms. This article summarizes their insights. See “How Designating TCOs As Terrorist Organizations Creates Risks for Financial Institutions and Beyond” (May 21, 2025).

A Baker’s Dozen AI Governance Resolutions for 2026

Many companies spent 2025 scrambling to integrate artificial intelligence (AI) into all aspects of business, just as a second transformative technology, which allows for independent decision-making by an AI agent, was entering early adoption. With pressure building throughout the business environment to incorporate these new technologies, the humans responsible for corporate AI efforts should pause at the start of 2026 to reflect on how risks have, and continue to, evolve. The Anti-Corruption Report spoke to experts about what company leaders should resolve to do for their AI governance efforts in 2026. They recommended a baker’s dozen practical resolutions for organizations to develop greater trust in their AI use, advance responsible AI development, mitigate the technology’s array of risks and respond in a balanced way to the AI-related pressure building inside and outside organizations. See “Risk and Compliance Survey Highlights the Role of Compliance in AI Governance” (Oct. 22, 2025).

A Quick Look at 2025 Anti-Corruption Enforcement Developments

2025 began with a new presidential administration in the U.S. and changes snowballed from there. President Donald Trump issued numerous executive orders rearranging U.S. policy priorities, which the DOJ used as a jumping-off point to set new white-collar enforcement focuses. Meanwhile, enforcers in other countries expressed their intention to set their own agendas with regard to bribery and corruption enforcement. This Quick Look provides a summary of the key 2025 developments in anti-corruption enforcement as a tool for practitioners moving into the new year. See “2025 in Review: White-Collar Enforcement the ‘Right Way’ Remains a Priority” (Dec. 17, 2025).

BCLP Welcomes Compliance and Investigations Partner in Chicago

Bryan Cave Leighton Paisner (BCLP) has announced that Katrina Hausfeld has joined as a partner in the firm’s litigation and investigations practice in Chicago. She arrives from DLA Piper. For commentary from Hausfeld, see “Risk Assessment for Trump 2.0: Reassessing in the Great American Reset” (Sep. 24, 2025); and “Risk Assessment for Trump 2.0: Who and When” (Nov. 5, 2025).

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Women to Watch: Contributions, Achievements and Observations of Outstanding Female Professionals

To mark International Women’s Day, women editors and reporters at ION Analytics interviewed outstanding women in the industries and jurisdictions we cover. In this part, Law Report Group editors Jill Abitbol, Robin L. Barton and Megan Zwiebel profile notable women in data privacy, cybersecurity, private funds and anti-corruption law, including Anne-Gabrielle Haie, Jessica Lee, Micaela McMurrough, Laura Perkins, Amanda Raad, Madelyn Calabrese, Ranah Esmaili and Genna Garver. Enjoy reading their inspiring remarks here.