Much of the guidance in Deputy AG Todd Blanche’s June 2025 memorandum laying out how to investigate and enforce the FCPA (Blanche Memo) is based on the idea that when a corporation is held responsible for the actions of its employees, there are collateral consequences for investors, shareholders and innocent employees. Knowing the DOJ will consider these collateral consequences may come as a relief to companies. However, there is an interesting tension between the approach outlined in the Blanche Memo and global trends toward increasing corporate responsibility. This second article in a two-part series explores the Blanche Memo’s directives for DOJ prosecutors to consider collateral consequences and move swiftly through investigations, as well as global trends in corporate accountability. The first part examined the interplay between individual prosecutions and collective knowledge theories of corporate liability under the second Trump administration. See “Insiders Tsao, Soltes and Kahn Share Insights on Investigations” (Jan. 4, 2023).