Annie Birch

The guidelines confirm that FCPA enforcement will continue but provide opportunities for foreign authorities to lead where US interests are not significantly impacted. On 9 June 2025, US Department of Justice (DOJ) Deputy Attorney General Todd Blanche issued a memorandum outlining guidelines (the Guidelines) for investigations and enforcement actions brought by DOJ under the Foreign Corrupt Practices Act (FCPA).

The updated guidance puts a heavy emphasis on self-reporting and clarifies how corporates under investigation can earn cooperation credit from UK prosecutors. On 24 April 2025, the UK Serious Fraud Office (SFO) published a long-awaited update to its Guidance on Corporate Co-operation and Enforcement (the Guidance). The Guidance outlines the agency’s key considerations when deciding whether to prosecute a corporate or invite it to negotiate a deferred prosecution agreement (DPA).

The ruling, which narrows the UK’s jurisdiction over money laundering offences, will impact how cross-border money laundering offences are prosecuted going forward. The UK Supreme Court’s decision in El-Khouri has clarified the territorial limits of the Proceeds of Crime Act 2002 (POCA).