Long Read · May 4, 2026 · 9 min

FCPA Enforcement After the 2026 Corporate Memorandum

The Department of Justice’s 2026 corporate-enforcement memorandum signals a meaningful recalibration of FCPA priorities. Multinational clients should reassess voluntary-disclosure posture in light of the framework.

The Department of Justice’s 2026 corporate-enforcement memorandum signals a meaningful recalibration of FCPA enforcement priorities. Counsel for multinational clients should reassess voluntary-disclosure posture, internal-investigation cadence, and the documentation supporting cooperation credit under the revised framework.