Ahead of schedule, after an executive order paused enforcement, Deputy AG Todd Blanche issued a memorandum in June 2025 providing guidelines for investigations and enforcement of the FCPA (Blanche Memo). It calls for a narrowed focus on bribery cases that “directly undermine[] U.S. national interests,” particularly with regard to cartels and transnational criminal organizations (TCOs). However, the language of the Blanche Memo regarding FCPA cases that are “associated with” TCOs may sweep in significantly more companies and behavior than might be expected. This article examines how the FCPA may be used to target the entire TCO ecosystem and how companies may need to adjust their compliance programs. See our two-part series on the FCPA executive order: “The Future of U.S. Enforcement” (Mar. 12, 2025), and “Staying the Course in the Face of Continued Risk” (Mar. 26, 2025).