The guidance on how the DOJ will enforce the FCPA during the second Trump administration, as described in a memorandum issued by Deputy AG Todd Blanche (Blanche Memo), details how the law can be used as a sword to cut down cartels and transnational criminal organizations (TCOs). However, it also describes the ways in which the DOJ may use the FCPA as a shield for American companies and industries against global competitors. This second article in a three-part series examining the Blanche Memo unpacks the directives to protect U.S. companies, use the FCPA to advance U.S. national security, and only investigate and prosecute the most serious misconduct. The first article discussed how the DOJ plans to use the FCPA to target the full TCO ecosystem. The final part will discuss what the Blanche Memo says about corporate responsibility. For more on the DOJ’s enforcement priorities, see “Assessing the Criminal Division’s New Enforcement Focuses” (Jun. 18, 2025).