Insights and Analysis

The FCPA Lives: Targeting the TCO Ecosystem

04 August 2025

On June 9, 2025 Deputy AG Todd Blanche issued a memorandum providing guidelines for FCPA investigations and enforcement (Blanche Memo). The Blanche Memo made clear that FCPA enforcement will continue, but prosecutors will be using it differently.

In this article examining the narrowed focus on bribery cases that “directly undermine U.S. national interests,” particularly with regard to cartels and transnational criminal organizations (TCOs) in the context of the Blanche Memo, Stephanie Yonekura, Khushaal Ved and Nikolaos Doukellis from our Investigations, White Collar and Fraud team were invited to share their insights on what this means for the enforcement landscape going forward.

Please click through to view the full article on the Anti-Corruption Report website:

The FCPA Lives: Targeting the TCO Ecosystem

Please note: this article is hosted on an external website and may be behind a paywall.

Authored by Megan Zwiebel (Anti-Corruption Report).