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Corruption Foreign Corrupt Practices Act (FCPA) Trump Administration

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

Whiteford

Client Alert: Attorney General Bondi Changes Direction on FCPA and FARA Prosecutions

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On her first day in office, Attorney General Pam Bondi announced several changes to the standards governing the exercise of prosecutorial discretion, charging decisions, plea negotiations and sentencing recommendations. Two...more

Torres Trade Law, PLLC

DOJ Memoranda Impact FCPA, FARA, and Other National Security Enforcement Priorities

President Trump’s pick for Attorney General, Pam Bondi, took quick action upon her swearing in on February 5, 2025, to make changes within the Department of Justice (“DOJ”) via the issuance of fourteen separate memorandum...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

Husch Blackwell LLP

New Executive Order Directs DOJ to Pause FCPA Enforcement

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On February 10, 2025, President Trump issued an executive order that instructed DOJ to pause all action related to enforcement of the Foreign Corrupt Practices Act (FCPA). Enacted in 1977, the FCPA features anti-bribery...more

Vedder Price

Changed Focus of FCPA Actions Under Trump Executive Order

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On February 5, 2025, newly appointed U.S. Attorney General Pam Bondi issued a memorandum titled “Total Elimination of Cartels and Transnational Criminal Organizations” (the February 5 Memorandum), which outlined a broad...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

Jenner & Block

Client Alert: The Trump Administration Calls for a Pause on New FCPA Enforcement, but Don’t Abandon Compliance Programs Just Yet

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In an executive order issued on February 10, 2025 (Executive Order), and a memorandum issued by Attorney General Pam Bondi regarding cartels and transnational criminal organizations on February 5, 2025 (Cartel Memo), the...more

Foley Hoag LLP

Trump Administration Pauses FCPA Enforcement – Why Compliance Is Still Critical

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On February 10, 2025, President Trump issued an executive order (EO) directing Attorney General Pam Bondi to effectively pause the Justice Department’s enforcement of the Foreign Corrupt Practices Act (FCPA). This was the...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

Kramer Levin Naftalis & Frankel LLP

President Trump Signs Executive Order Pausing Enforcement Under the FCPA; Attorney General Bondi Issues 14 Memoranda Realigning...

On Feb. 10, President Donald Trump issued an executive order pausing enforcement under the Foreign Corrupt Practices Act (FCPA or the Act) for a period of at least 180 days and up to 360 days. The order directs Attorney...more

Alston & Bird

Trump Administration Halts New FCPA Enforcement, Will Review Open Investigations

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In a move that sent shockwaves through the world of white collar corporate defense, President Trump has issued an Executive Order instructing the Attorney General to pause new FCPA enforcement subject to review existing FCPA...more

Skadden, Arps, Slate, Meagher & Flom LLP

Anti-Bribery and Corruption Risks Remain Despite FCPA Enforcement Pause

On February 10, 2025, President Donald Trump signed an executive order directing the U.S. attorney general, Pam Bondi, to pause Foreign Corrupt Practices Act (FCPA) actions for 180 days until she issues revised FCPA...more

Snell & Wilmer

Reevaluating the Foreign Corrupt Practices Act Enforcement: A New Paradigm

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On February 10, 2025, President Trump signed an Executive Order (E.O.) directing a shift in the enforcement of the Foreign Corrupt Practices Act (FCPA). The order effectively pauses new FCPA investigations and enforcement...more

Holland & Knight LLP

FCPA Enforcement on Pause Per Executive Order

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Just over two months ago, the Kansas City Chiefs were still two-time defending Super Bowl champions, Luka Doncic was a Dallas Maverick, and the U.S. Department of Justice's (DOJ) Foreign Corrupt Practices Act (FCPA) Unit was...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

Morrison & Foerster LLP

FCPA Enforcement Under the Second Trump Administration

Since its enactment in 1977, the FCPA has been the primary legal mechanism in the United States for preventing and punishing corrupt business practices around the world. At a high-level, the FCPA applies to both domestic and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Trump Orders Attorney General To Temporarily Pause FCPA Enforcement

On February 10, 2025, President Donald Trump issued an executive order directing the attorney general to pause, for a period of 180 days, new enforcement actions under the Foreign Corrupt Practices Act (FCPA). The federal...more

WilmerHale

President Trump and Attorney General Bondi Announce Significant Shift in FCPA and Other Corporate Enforcement Priorities

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Soon after being sworn in, President Trump issued Executive Orders identifying top administration priorities: combating illegal immigration, drug cartels, and unlawful DEI practices. Taking a similar tack, on her first day in...more

Latham & Watkins LLP

President Trump Issues Executive Order Pausing Foreign Corrupt Practices Act Enforcement at DOJ

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The order pauses new FCPA criminal cases, directs review of existing cases, and leaves open several questions, including implications for specific business sectors and civil enforcement....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

McGuireWoods LLP

Major Shift on Foreign Corrupt Practices Act: Trump Signs EO Pausing Enforcement

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Last night, in a move with wide-ranging implications for American companies doing business abroad, President Trump issued an executive order (Order) temporarily halting enforcement of the Foreign Corrupt Practices Act (FCPA)....more

Fox Rothschild LLP

Trump Executive Order Pauses FCPA Enforcement

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Raising questions about the future of U.S. anti-corruption policy, President Trump has temporarily paused enforcement of the Foreign Corrupt Practices Act (FCPA),. An Executive Order (EO) signed on Feb. 10, 2025, Pausing...more

The Volkov Law Group

1 MDB Corruption Scandal Ripples with Superseding Indictment of Jho Low and Former Rapper “Pras’ Michael for Back-Channel Attempt...

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The scandal emanating from the 1 Malaysia Development Berhad fund (1MDB) continues to ripple through criminal law enforcement and criminal prosecutions. ...more

Sheppard Mullin Richter & Hampton LLP

The Next Four Years of FCPA Enforcement: What to Expect From the Biden Administration

Contrary to some expectations, the Trump Administration Department of Justice imposed record penalties under the U.S. Foreign Corrupt Practices Act from 2017 through 2020. But in each of those years, fewer and fewer new FCPA...more

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