The new DOJ FCPA enforcement policy emphasizes US national security and business interests, moving away from solely prosecuting bribery of foreign officials. The focus will be on bribes involving Transnational Criminal Organizations (TCOs), cartels, and those impacting US competitiveness or national security. Routine, locally accepted business practices are deprioritized. The DOJ will exercise discretion to determine if conduct genuinely impacts US interests, leaving other cases to the SEC or foreign regulators. This creates a more nuanced and unpredictable enforcement environment, with clarity expected only as enforcement patterns emerge.
On 9 July 2015, the Government Gazette published Amendment No. 3 to the Anti-Corruption Law, 1999, which came into effect on 10 July 2015. The reason for this amendment is to comply with international standards for prevention and suppression of corruption, which Thailand ratified under the treaty of the United…