News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Regulatory Reform

Hogan Lovells

Brazil – a new ally for the enforcement avengers? Brazil collaborating with China on anti-corruption enforcement

Hogan Lovells on

At a legal industry event on 9 April 2025, Marcelo Pontes Vianna, the head of the secretariat for private integrity of Brazil's Office of the Comptroller General (CGU), the national antibribery agency, highlighted Brazil's...more

White & Case LLP

SEC Enforcement 2.0: Chairman Atkins Has Arrived

White & Case LLP on

Paul Atkins has taken the reins of the US Securities and Exchange Commission (SEC). After being confirmed by the Senate on April 9, Atkins officially began his tenure as SEC Chairman on April 21. His arrival is expected to...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

Thomas Fox - Compliance Evangelist

Compliance into the Weeds: The Role of Compliance Going Forward

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some...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

Zuckerman Spaeder LLP

The False Claims Act Could Become the New “It” Statute in an Uncertain Enforcement Landscape

Zuckerman Spaeder LLP on

Uncertainty was a prominent theme at last week’s ABA White Collar Crime Institute. The Trump administration has issued a series of directives that seem to shift and narrow the scope of (if not entirely abandon) a host of...more

Torres Trade Law, PLLC

President Trump Pauses FCPA Enforcement

On February 10, 2025, President Trump issued an Executive Order on “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security” (“the E.O.”). The E.O. orders Attorney General, Pam...more

Seyfarth Shaw LLP

Navigating Trump’s FCPA Enforcement Pause: Strategic Recommendations for Corporate Leaders

Seyfarth Shaw LLP on

President Trump’s February 10th Executive Order (EO) titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security,” has introduced significant uncertainty into FCPA enforcement....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

Latham & Watkins LLP

Executive Order Pauses FCPA Enforcement at DOJ: Key Takeaways on Immediate Impact

Latham & Watkins LLP on

Insights and open questions for companies seeking to promote anti-corruption compliance in a dynamic regulatory environment. On February 10, 2025, the Trump administration issued an executive order (the Order) taking aim...more

Jenner & Block

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

Jenner & Block on

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

McCarter & English, LLP

Trump Administration Shifts DOJ’s Approach to FCPA Enforcement

On February 10, 2025, President Trump signed an Executive Order (EO) directing Attorney General Pam Bondi to halt ongoing enforcement by the Department of Justice (DOJ) in all active prosecutions brought pursuant to the...more

Ballard Spahr LLP

Attorney General Bondi Overhauls Justice Priorities

Ballard Spahr LLP on

The new administration has signaled that the Department of Justice (“DOJ”) will significantly shift its approach to criminal corporate enforcement. Specifically, on February 5, 2025, newly-confirmed United States Attorney...more

The Volkov Law Group

Sifting Through the Rubble — What to Make of the Topsy-Turvey World of FCPA Enforcement?

The Volkov Law Group on

The dust is settling and for all the drama surrounding the Trump Administration’s refocus on FCPA enforcement, the picture is becoming a little bit clearer.  When cooler heads prevail, it is much easier to pick through the...more

Cozen O'Connor

U.S. Dials Back Implementation of Foreign Corrupt Practices Act

Cozen O'Connor on

On February 10, 2025, President Trump signed an executive order instructing the Department of Justice (DOJ) and Attorney General (AG) Pamela Bondi to “cease initiation of any new [Foreign Corrupt Practices Act (FCPA) (15...more

Alston & Bird

Trump Administration Halts New FCPA Enforcement, Will Review Open Investigations

Alston & Bird on

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

Porter Hedges LLP

Breaking Alert: New Executive Order Temporarily Pauses FCPA Enforcement

Porter Hedges LLP on

On February 10, 2025, President Trump signed an executive order (EO) directing the Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days. During this period, Attorney...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

Proskauer Rose LLP

Back to the Future: Protection of Foreign Affairs Focus for FCPA Enforcement

Proskauer Rose LLP on

Under the guise of protecting the President’s authority to conduct foreign affairs, on February 10, 2025, President Donald J. Trump signed an Executive Order pausing enforcement of the U.S. Foreign Corrupt Practices Act...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

Jones Day

President Trump Pauses DOJ FCPA Enforcement and Orders Preparation of New Enforcement Guidelines

Jones Day on

On February 10, 2025, President Donald J. Trump signed an Executive Order pausing enforcement of the Foreign Corrupt Practices Act ("FCPA") by the U.S. Department of Justice ("DOJ") for 180 days and ordering Attorney General...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

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

Perkins Coie

Trump Halts FCPA Enforcement, for Now, and Appears to Open Pathway to Reexamine Prior FCPA Settlements

Perkins Coie on

The Foreign Corrupt Practices Act (FCPA), passed in the wake of Watergate, prohibits U.S.-linked companies and individuals from bribing foreign government officials to procure international business and hiding the bribes in...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

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