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June 18, 2025 31 mins
Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this episode of ‘All Things Investigations,’ host Tom Fox is joined by Mike DeBernardis to discuss the recent guidelines released by Deputy Attorney General Todd Blanche on the enforcement of the Foreign Corrupt Practices Act (FCPA). They dissect the new memorandum, its implications for corporate investigations, and the focus on eliminating cartels and transnational criminal organizations. The conversation also delves into topics such as competitive advantage, the role of national security in FCPA enforcement, and the strategic implications for companies. The episode concludes with insights on how companies and their legal counsel should navigate these updated guidelines and prepare for a more expedited and focused investigation process. Key highlights: Overview of New FCPA Guidelines Focus on Competitive Advantage Prosecutorial Considerations National Security and Strategic Business Prioritizing Serious Misconduct Advising Clients on FCPA Compliance Resources: Mike DeBernardis Hughes Hubbard & Reed website HHR Client Alert: DOJ Ends FCPA Enforcement Pause
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