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).
