When Deputy AG Todd Blanche issued his memorandum laying out guidelines for investigation and enforcement of the FCPA (Blanche Memo) in June 2025, the headline news was that the FCPA will be used both as a sword and shield to promote American interests. However, there is a more existentially interesting element to the Blanche Memo regarding how this administration and its enforcers view corporations’ role in American society. This two-part article series examines what the Blanche Memo indicates about corporate responsibility during the second Trump administration, with this first installment focusing on the interplay between individual prosecutions and collective knowledge theories of corporate liability. The second article will examine how the Blanche Memo might be at odds with global trends and the emphasis it places on the collateral harm caused by investigations and prosecutions. See “DOJ’s New VSD Program Offers NPAs to Individuals Who Can Help Catch Bigger Fish” (May 8, 2024).