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Foreign Corrupt Practices Act (FCPA) Anti-Corruption Securities and Exchange Commission (SEC)

Husch Blackwell LLP

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

Husch Blackwell LLP on

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

King & Spalding on

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

Mayer Brown

The Future of Anti-Corruption Enforcement: Potentially Increasing State and Non-US Prosecutions as an Alternative to the FCPA

Mayer Brown on

On February 10, 2025, President Donald Trump signed an executive order instructing the United States Department of Justice (“DOJ”) to pause enforcement of the Foreign Corrupt Practices Act (“FCPA”) for a period of 180 days....more

Miller Nash LLP

FCPA Update: Enforcement Landscape Shifts Under New Executive Order

Miller Nash LLP on

As a follow-up to our previous article, "To Tariff, or Not to Tariff?", President Trump issued an Executive Order on February 10, 2025, directing the Attorney General to review the current guidelines and enforcement policies...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

Hinshaw & Culbertson - Consumer Financial...

An In-House Compliance Guide for Responding to President Trump's Executive Order on Foreign Corrupt Practices Act Enforcement

As has widely been published, on February 10, 2025, President Trump signed Executive Order (EO) 14209, which paused all future investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA) for at least...more

Ankura

Internal Control Lessons Learned from Global Anti-Corruption Enforcement in 2024

Ankura on

2024 saw another strong year of Foreign Corruption Practices Act (FCPA) enforcement actions from the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). There were 15 resolutions with...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

Ankura

The Extended Network: Managing Third Parties' Bribery Risks

Ankura on

Approximately 90% of U.S. Foreign Corrupt Practices Act (FCPA) enforcement cases from its inception in 1978 have involved third-party intermediaries engaging in bribery schemes. The reduced level of control or oversight...more

Lathrop GPM

Trump Executive Order Pausing FCPA Enforcement: Have Legal Requirements Changed?

Lathrop GPM on

One of the most notable developments in the anti-corruption world is the Trump Administration’s Feb. 10 Executive Order, “Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security.” ...more

Maynard Nexsen

Despite FCPA Enforcement Pause, Anti-Corruption Should Remain a Compliance Priority

Maynard Nexsen on

On February 10, 2025, President Donald J. Trump issued an Executive Order instructing the Department of Justice (DOJ) to temporarily pause Foreign Corrupt Practices Act (FCPA) enforcement and reconsider its enforcement...more

Husch Blackwell LLP

New Executive Order Directs DOJ to Pause FCPA Enforcement

Husch Blackwell LLP on

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

Troutman Pepper Locke

Trump Pauses FCPA Enforcement: Implications for Corporate Compliance Strategies

Troutman Pepper Locke on

On February 10, President Donald J. Trump signed an executive order and accompanying fact sheet directing U.S. Attorney General (AG) Pam Bondi to pause the initiation of new investigations and enforcement actions, and to...more

Carlton Fields

President Trump Issues Executive Order Pausing Enforcement of FCPA: A Sea Change Moment for DOJ and SEC

Carlton Fields on

On February 10, 2025, President Trump issued Executive Order 14209, titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security,” with the stated purpose of eliminating...more

Foley Hoag LLP

Trump Administration Pauses FCPA Enforcement – Why Compliance Is Still Critical

Foley Hoag LLP on

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

McGuireWoods LLP

Practical Tips for Companies Following President Trump’s Pause on FCPA Enforcement

McGuireWoods LLP on

Since the President signed the February 10, 2025 Executive Order (Order) pausing enforcement of the Foreign Corrupt Practices Act (FCPA) (Client Alert: President Trump issues Executive Order “Pausing Foreign Corrupt Practices...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

Morgan Lewis

President Trump Issues Executive Order Temporarily Pausing FCPA Enforcement

Morgan Lewis on

President Donald Trump recently released an executive order temporarily halting Foreign Corrupt Practices Act investigations and enforcement actions....more

Benesch

President Trump “Pauses” FCPA Enforcement: What This Means for Legal & Compliance Departments

Benesch on

On February 10, 2025, President Trump issued an Executive Order entitled Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security. The executive order comes just days after the...more

Wiley Rein LLP

What the FCPA Criminal Enforcement Pause Means for Companies

Wiley Rein LLP on

Late on February 10, President Trump ordered Attorney General Pam Bondi to “pause” new Foreign Corrupt Practices Act (FCPA) enforcement for 180 days while the U.S. Department of Justice (DOJ) refocuses criminal enforcement of...more

Baker Botts L.L.P.

Yes, Bribes Are Still Illegal, and Other Takeaways from the Pause on Foreign Corrupt Practices Act Enforcement

Baker Botts L.L.P. on

On February 10, 2025 President Trump issued an executive order titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” The order directs the DOJ to halt Foreign Corrupt...more

Kilpatrick

President Trump Hits "Pause" (But Not "Stop"): The Scope of the New Executive Order on The DOJ's FCPA Enforcement Against American...

Kilpatrick on

Key Takeaways: The Executive Order’s 180-day pause on the DOJ’s FCPA enforcement does not eliminate many corruption and bribery risks. The Executive Order is limited in that it does not currently affect enforcement by...more

McGuireWoods LLP

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

McGuireWoods LLP on

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

Fox Rothschild LLP on

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

Katten Muchin Rosenman LLP

U.S. Attorney General Issues Memorandum Redirecting FCPA Enforcement Away From U.S. Businesses

In a memorandum dated Feb. 5, 2025, U.S. Attorney General Pamela Bondi has instituted a novel approach to enforcing the Foreign Sovereign Immunities Act (FCPA). The FCPA prohibits paying or offering to pay money or...more

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