DOJ Reaffirms FCPA and White-Collar Enforcement Priorities at the ACI FCPA Conference in Washington, D.C.
DOJ Reaffirms FCPA and White-Collar Enforcement Priorities at the ACI FCPA Conference in Washington, D.C.
A renewed focus on cases that “matter to the American people” — and why companies must accelerate investment in investigative technology
The annual ACI FCPA Conference hosted the first week of December, in Washington, D.C. once again served as the year’s most important platform for U.S. enforcement authorities to outline their priorities in foreign bribery, white-collar crime, and cross-border investigations. This year’s conference delivered a particularly clear message: “The Department of Justice is recalibrating its enforcement efforts to focus on cases that cause real, measurable harm to U.S. interests — and companies must be prepared to meet that expectation with stronger compliance and more advanced technology.”
Multiple senior DOJ officials — including Deputy Attorney General Todd Blanche, Acting AAG Matthew Galeotti, and Acting Chief Counselor Keith Edelman — underscored the Department’s renewed focus on meaningful, consequential enforcement. Their remarks signaled a shift away from sprawling, abstract theories of liability and toward cases that directly affect the United States, its consumers, and its markets.
As Acting AAG Galeotti stated, DOJ intends to prioritize “things that matter to the American people,” which includes:
- Foreign bribery that distorts competition and harms U.S. companies
- Schemes involving cartels and transnational criminal organizations (TCOs) that use corruption, extortion, and infiltration to gain access to U.S. supply chains
- Cases where U.S. investors, employees, or consumers suffer harm
- White-collar misconduct involving national security implications, data security risks, or foreign influence
- Corporate misconduct tied to money laundering, sanctions evasion, and illicit finance
Deputy Attorney General Blanche reinforced this principle by highlighting the need for evidence-based, disciplined enforcement that brings accountability to individuals, not just corporations. Edelman added that DOJ is intent on pushing cases forward faster, focusing on credible, provable misconduct tied to identifiable decision-makers.
DOJ is signaling a “quality over quantity” approach: fewer cases overall, but more impactful ones — cases that resonate with U.S. stakeholders and protect U.S. markets.
The Growing Threat of Cartels and Transnational Criminal Organizations, Potentially in LATAM
Throughout the conference—and especially during the dynamic panel moderated by María Gallo of TransPerfect Legal—it became clear that practitioners across the industry share DOJ’s deep concern regarding the accelerating convergence between FCPA violations, white-collar misconduct, and organized criminal networks. As the panelists emphasized, this is no longer a theoretical discussion. Over the past several years, cartels and transnational criminal organizations have transformed from traditional criminal groups into highly sophisticated economic actors. They study supply chains. They identify corporate vulnerabilities. And they have learned that the most effective way to expand their influence is by quietly infiltrating legitimate businesses—strategically, methodically, and often through complex layers of intermediaries. The panel concluded with a powerful message: companies must recognize this new reality and adapt their compliance, due-diligence, and investigative frameworks accordingly, or risk becoming conduits for criminal activity without ever seeing it coming.
This infiltration increasingly occurs through:
- Front companies and opaque intermediaries
- Corrupt procurement and vendor-onboarding schemes
- Cyber-enabled extortion and data-theft operations
- Manipulation of logistics providers and local partners
- Violence, intimidation, or coercion targeting employees in high-risk jurisdictions
DOJ officials made clear that many of the most consequential FCPA-related harms now arise from this intersection of corruption and organized crime, particularly across Latin America. This warning resonated strongly with practitioners throughout the region, underscoring the urgent need for enhanced due diligence, stronger controls, and technology-driven monitoring to keep criminal networks out of corporate supply chains.
We are at a moment where due diligence and internal investigations can no longer rely on paper checklists, manual reviews, or fragmented processes. The risks companies face today—especially from sophisticated criminal networks—require a far more advanced approach. Corporations must begin integrating Generative AI, traditional AI, machine learning, and advanced analytics to truly understand their organizations end-to-end. We are no longer searching blindly for “a term that may or may not appear” in a dataset; instead, we must uncover the patterns, relationships, intent, and behavioral signals hidden within communications, transactions, client interactions, and vendor networks. Effective investigations now demand bringing together the company’s data, systems, and management insights to detect anomalies, map risk, and identify wrongdoing early. In this environment, technology is not optional—it is the foundation of a modern, defensible, and proactive internal investigation function.
The Corporate Imperative: Invest in Technology or Fall Behind
A major theme echoed by DOJ leadership — though not as a formal mandate — was unmistakable: “Companies must dramatically improve their technological capabilities if they want to meet DOJ’s expectations for compliance and investigations.”
In today’s enforcement landscape, a modern compliance program is impossible without:
- Robust data controls across borders
Global companies generate enormous volumes of data, often stored in multiple jurisdictions with conflicting privacy rules. DOJ officials reiterated that companies must be able to:
- Identify where their data resides
- Preserve it quickly
- Produce it in usable, searchable formats
- Implement defensible retention and deletion policies
- Prevent deliberate “data dispersion” by wrongdoers
Technology is no longer optional here, it is a MUST!
- Advanced review and analytics
With investigations involving tens or hundreds of millions of documents, traditional review models are obsolete. Companies need:
- AI-powered data reduction
- Automated pattern detection
- Multilingual review capabilities
- Real-time monitoring and early-warning signals
- Analytics tools capable of identifying suspicious relationships, payments, and communications.
DOJ expects companies to be able to surface the “who, what, and why” quickly — and technology is the only realistic way to do it.
- Monitoring of supply-chain risk
Given DOJ’s focus on cartel and TCO infiltration, companies must integrate:
- Supplier risk scoring
- Continuous due diligence
- Behavioral anomaly detection
- Beneficial ownership analytics
- Geographic risk mapping
The message is simple: a spreadsheet-based compliance program cannot protect a modern supply chain.
- Technology-driven internal investigations
In an era of global data, remote work, encrypted platforms, and cross-border messaging apps, companies must be able to conduct:
- Forensic data collection
- Analytics-driven scoping
- Rapid filtering
- Secure, global review
- Coordinated legal analysis across jurisdictions
Technology accelerates investigations, reduces costs, and directly affects how regulators view cooperation efforts.
What This Means for Companies Going Forward
The DOJ’s remarks at the conference were not merely directional — they were a roadmap:
- Enforcement is becoming more targeted and more consequential. Cases tied to U.S. markets, supply chains, investors, and employees will receive priority.
- Companies must modernize their compliance and investigative ecosystems. Outdated systems create blind spots — and DOJ will expect companies to eliminate them before problems arise.
- Technology investment is now a core compliance requirement. The ability to trace data, identify misconduct, and mitigate risk is inseparable from the use of analytics, AI, and digital investigation platforms.
- High-risk jurisdictions demand enhanced controls. In Latin America, Asia, Africa, and emerging markets, companies must be prepared to face TCOs, government corruption, cyber-enabled fraud, and complex data privacy challenges.
Act Now or Risk Exposure: The Corporate Imperative for 2025
The 2025 ACI FCPA Conference made one thing clear: FCPA and white-collar enforcement are not slowing down — they are becoming more focused, more strategic, and more technologically driven.
As DOJ leadership emphasized, the Department is committed to pursuing cases that meaningfully protect U.S. interests. For companies, this means investing now in the technology, data-governance, and investigative infrastructures that regulators increasingly view as essential.
Those who act early will be far better positioned to mitigate risk, cooperate effectively, and navigate an enforcement environment that is only growing more complex.
Ready to modernize your compliance and investigations workflow? Get in touch with our team.