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Foreign Corrupt Practices Act (FCPA) Trump Administration Corporate Governance

DarrowEverett LLP

The DOJ’s New White-Collar Agenda: Implications for Businesses

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On May 12, 2025, the Department of Justice (the “DOJ”) released its criminal—and, more specifically, white collar crime enforcement—initiatives under the current administration. This is typical each time new leadership...more

Kramer Levin Naftalis & Frankel LLP

DOJ Announces White-Collar Enforcement Priorities and Revised Corporate Enforcement & Voluntary Self-Disclosure Policy

On May 12, 2025, the Department of Justice (“DOJ” or the “Department”) issued a revised Corporate Enforcement and Voluntary Self-Disclosure Policy (Revised CEP). Matthew R. Galeotti, chief of the Criminal Division of the DOJ,...more

The Volkov Law Group

This is Not the Time to Retreat on Compliance

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Call me an optimist — it is a much better alternative than being a pessimist or a “realist” with a pessimistic bent. So, let’s start by acknowledging the obvious. Businesses are operating in a volatile environment. The...more

DLA Piper

Key Considerations for Compliance Officers Under President Trump

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The Trump Administration has ushered in massive shifts in enforcement and policy priorities. From crypto to anti-corruption measures and tariffs to technology, the new Administration has changed the compliance landscape...more

Jenner & Block

Jenner & Block Japan Newsletter - April 2025

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Welcome to the April 2025 edition of the Jenner & Block Japan Newsletter, a publication containing updates about legal developments in the United States that may be noteworthy to our clients and other leaders in the Japanese...more

Miles & Stockbridge P.C.

Despite Reduced Enforcement Risks, Businesses Should Invest in Corporate Compliance

Some early actions by the Trump administration have led corporate legal departments to question the extent to which they need to invest in ethics and compliance at this time, based on a perceived reduction in enforcement...more

NAVEX

California Reminds Businesses Bribery is Illegal – Why Other States Should Follow Suit

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On February 10, 2025, President Trump issued an  executive order pausing federal enforcement over the U.S. Foreign Corrupt Practices Act by ordering the U.S. Attorney General to “cease initiation of any new FCPA...more

Thomas Fox - Compliance Evangelist

Upping Your Game: Episode 1 – Meeting Hui Chen’s Challenge

In February, the Trump Administration suspended investigations under and enforcement of the FCPA. Many compliance professionals have since wondered what this will mean for corporate compliance programs going forward. Hui Chen...more

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

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

Skadden, Arps, Slate, Meagher & Flom LLP

California Attorney General Warns That FCPA Violations Are Still Actionable Under State Law

Key Points -- - The FCPA remains valid and enforceable U.S. law, and violations of the law may serve as a predicate offense under state and local laws. - Companies should be prepared for continued enforcement of...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

Seyfarth Shaw LLP

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

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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

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

Ballard Spahr LLP

Attorney General Bondi Overhauls Justice Priorities

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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?

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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

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

Morgan Lewis

President Trump Issues Executive Order Temporarily Pausing FCPA Enforcement

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

Wiley Rein LLP

What the FCPA Criminal Enforcement Pause Means for Companies

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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

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

Nelson Mullins Riley & Scarborough LLP

Bribers, Start Your Engines or Pump the Brakes?

Five Fast Reminders as Trump Pauses FCPA Enforcement - Late on February 10, 2025, President Trump issued an Executive Order (“EO”) instructing the Attorney General to pause Foreign Corrupt Practices Act (“FCPA”)...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

Perkins Coie

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

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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

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