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Bribery Foreign Corrupt Practices Act (FCPA) Trump Administration

Husch Blackwell LLP

State Attorneys General May Step Up Foreign Anti-Corruption Enforcement Efforts Following Federal Enforcement Pause

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For decades Foreign Corrupt Practices Act (FCPA) enforcement has been largely considered a federal matter, with the U.S. Department of Justice (DOJ) enforcing the statute’s criminal provisions.[1] Enacted in 1977, FCPA...more

King & Spalding

Anti-Bribery and Anti-Corruption Enforcement in the U.S., UK, and Europe post-FCPA Pause

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We have previously written about the impact of the pause in enforcement of the FCPA implemented by the Trump Administration on non-American companies.1 Although the 180-day review period the Executive Order provided to the...more

White & Case LLP

A Vested Interest in Honest Business: California Attorney General Reminds Businesses that FCPA Violations Remain Actionable under...

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On April 2, 2025, California Attorney General Rob Bonta issued a Legal Advisory reminding businesses operating in California that foreign bribery remains illegal under California law and that violations of the US Foreign...more

Wilson Sonsini Goodrich & Rosati

California AG Warns Companies That FCPA Violations Are Still Enforceable Notwithstanding Federal Pause

On April 2, 2025, California Attorney General Rob Bonta issued a press release and legal advisory reminding businesses operating in California that violations of the Foreign Corrupt Practices Act (FCPA) are still actionable...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for March 2025

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Hogan Lovells

DOJ's pause on FCPA is a compliance shake up for businesses

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This article was originally published by Bloomberg Law on April 10, 2025, and is republished here with permission. Read the original article here: DOJ’s Pause on FCPA Is a Compliance Shake-Up for Businesses – Bloomberg Law. ...more

Dechert LLP

Eurostars Align to Tackle Corruption

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Formation of new anti-corruption alliance in Europe and what it means for international enforcement - On 20 March 2025, the UK Serious Fraud Office (SFO), French Parquet National Financier (PNF) and the Office of the...more

Baker Donelson

DOJ Dismisses FCPA Charges Against Former Cognizant Executives Following New Policy

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On April 2, 2025, the U.S. Department of Justice (DOJ) moved to dismiss the Foreign Corrupt Practices Act (FCPA) case against former Cognizant Technology Solutions Corp. executives Gordon Coburn and Steven Schwartz, United...more

Bracewell LLP

US Halt on Foreign Anti-Corruption Enforcement Prompts New European Taskforce

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Approximately two weeks ago, British, French and Swiss law enforcement authorities announced the creation of a new international alliance. With their joint Founding Statement (“Statement”), the three countries established the...more

A&O Shearman

Criminal Case Against Former Executives Of Technology Company Dismissed

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On April 2, 2025, the Department of Justice moved to dismiss with prejudice its Foreign Corrupt Practices Act (“FCPA”) case against two former executives of a technology solutions company (“Company”). The executives were...more

Barnea Jaffa Lande & Co.

Trump’s Order May Refocus FCPA Enforcement on Foreign Competitors

President Trump’s recent Executive Order (EO), which seeks to reduce enforcement of the anti-bribery and anti-corruption provisions of the Foreign Corrupt Practices Act (“FCPA”), may be perceived as a declaration of an...more

Womble Bond Dickinson

UK, France, and Switzerland Form International Anti-Corruption Prosecutorial Task Force to Combat Anti-Corruption

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On February 5, 2025, Attorney General Pamela Bondi issued a memo requiring DOJ’s Foreign Corrupt Practice Act (“FCPA”) Unit to “prioritize investigations related to foreign bribery that facilitates the criminal operations of...more

Thomas Fox - Compliance Evangelist

Regulatory Ramblings: Episode 65 – The Trump Administration’s Decision to Halt FCPA Enforcement – The Implications for Asia and...

Three weeks after returning to the White House, US President Donald Trump signed an executive order on February 10 directing the Justice Department to pause prosecutions of Americans accused of bribing foreign government...more

A&O Shearman

US Attorney For The District of New Jersey Reverses Course And Requests Adjournment For Foreign Bribery Case Against Tech...

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On March 4, 2025, one day before a trial against former tech executives for alleged foreign bribery charges was set to commence, the United States Attorney for the District of New Jersey requested 180-day adjournment. The...more

Stikeman Elliott LLP

Foreign Bribery: The Bottom Line is that It’s Still Illegal Under Canadian Law

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It remains illegal under the Canadian Corruption of Foreign Public Officials Act (“CFPOA”) to bribe foreign officials. While this statement may be self-evident, recent developments south of the border prompt this reminder to...more

Pillsbury Winthrop Shaw Pittman LLP

Reshaped Priorities: Navigating Changes to FCPA and FARA Enforcement

On February 10, 2025, President Donald Trump signed an Executive Order directing the Department of Justice (DOJ) to pause enforcement of the U.S. Foreign Corrupt Practices Act (FCPA), citing concerns over the competitive...more

ArentFox Schiff

Investigations Newsletter: President Trump Puts a “Pause” on FCPA Enforcement

ArentFox Schiff on

President Trump Puts a “Pause” on FCPA Enforcement - On Monday, President Donald Trump signed an executive order (EO) pausing the enforcement of the Foreign Corrupt Practices Act (FCPA). According to the EO, the pause will...more

Vinson & Elkins LLP

Future of FCPA Enforcement Uncertain (For Now) as New Administration Revamps the Law Enforcement Toolkit

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Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more

American Conference Institute (ACI)

An FCPA Enforcement Pause Does Not Pause Anti-Corruption Compliance

U.S. Foreign Corrupt Practices Act (FCPA) enforcement activity may be at a temporary standstill, but that should not mean much for the day-to-day operations of global anti-corruption compliance programs. If the Department of...more

BakerHostetler

Why Your Company Still Needs to Care About the FCPA (& FEPA)

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This shift in FCPA enforcement priorities is the latest move by the administration in its all-out war against cartels and TCOs that pose a threat to U.S. national security and its stated America First agenda. Additionally,...more

Eversheds Sutherland (US) LLP

Executive Order signals major shift in FCPA enforcement—for now

President Trump’s February 10, 2025 Executive Order pausing Foreign Corrupt Practices Act (FCPA) enforcement and ordering an overhaul of FCPA policy marks a significant shift by the Department of Justice (DOJ), at least in...more

Paul Hastings LLP

Keep Calm and Carry On: Thoughts on Recent Orders on FCPA Enforcement

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What in the world is happening with enforcement of the Foreign Corrupt Practices Act (FCPA)? And what does the recent executive order (EO) and Department of Justice (DOJ) guidance mean for U.S. and global companies? Our view...more

Lowenstein Sandler LLP

Long Live the FCPA?

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The Trump administration has taken significant action this week to overhaul the executive branch’s long-standing policy toward the prosecution of white collar offenses. First, a memo issued by newly confirmed U.S. Attorney...more

The Volkov Law Group

Taking Stock of the FCPA Fallout (Part III of V)

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What an amazing turn of events? — Who would have predicted that the Trump Administration would take such a bold action in the name of advancing “American Competitiveness.” I admit I did not see this coming — the Trump...more

DLA Piper

President Trump’s Executive Order Pauses FCPA Enforcement Pending Attorney General Review

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On February 10, 2025, President Donald Trump signed an Executive Order (EO) directing Attorney General (AG) Pam Bondi to pause enforcement of the Foreign Corrupt Practices Act (FCPA) until new enforcement guidelines and...more

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