FCPA Priorities Whitepaper

Ground Truth Intelligence’s whitepaper examines the shift in FCPA enforcement following the DOJ’s 180-day pause and updated guidelines issued in June 2025. The new enforcement priorities refocus resources away from routine violations toward corruption that threatens US national security, economic competitiveness and cases tied to organized crime.

Key insights for compliance teams:

• The DOJ’s updated approach targets high-stakes corruption rather than routine grease payments, concentrating on wrongdoing linked to cartels, militias and corrupt foreign officials.
• Due diligence teams must sharpen their focus on third parties in cartel-prone regions or strategic sectors, moving these red flags from the back burner to urgent priority.
• AI-driven tools and open source intelligence can uncover shell companies, offshore links and suspicious payment trails that signal elevated risk.
• Self-reporting and swift action continue to mean leniency, making early detection and cooperation critical for compliance programs.