This session looks at how the Criminal Division's policies around enforcement have evolved under new leadership. Panellists will explore how enforcement guidelines and policies from 2025 have evolved in the first few months of 2026 and what companies must do to stay aligned. Including: 

• Whether the priorities outlined in the 2025 FCPA enforcement guidelines have stayed consistent  
• Understanding compliance programme benchmarks and how to meet evolving DOJ expectations 
• The DOJ's focus on whistleblowers and how companies should adapt their own whistleblower programmes  
• The ongoing potential risks and benefits of making a voluntary self-disclosure  
• What is next on the enforcement horizon under new leadership?