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Foreign Corrupt Practices Act (FCPA) Trump Administration Securities and Exchange Commission (SEC)

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

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

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

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

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

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

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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

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

Troutman Pepper Locke

Trump Pauses FCPA Enforcement: Implications for Corporate Compliance Strategies

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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

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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

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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

ArentFox Schiff

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

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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

Polsinelli

A Changing Enforcement Landscape Under the New Administration

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As the Trump Administration embarks on its second term, significant shifts in government enforcement priorities are quickly taking shape. Not surprisingly, this administration appears to be focusing on immigration, drug and...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

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

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

Kilpatrick

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

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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

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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

WilmerHale

FCPA Year-in-Review: 2024 Developments and Predictions for 2025

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Foreign Corrupt Practices Act (FCPA) enforcement activity increased overall in 2024, with a notable uptick in Department of Justice (DOJ) enforcement actions compared to 2023, despite a decrease in public Securities and...more

The Volkov Law Group

FCPA Predictions: Don’t Expect Much to Change

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In 2017, when President Trump first took office, big changes were expected in FCPA enforcement.  Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA.  He was not a big fan of the law and...more

Vinson & Elkins LLP

New Year and New Administration: DOJ Races to Clear Its FCPA Docket Before the Trump Administration Begins

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As we approach Inauguration Day on January 20, 2025, one question among anticorruption practitioners is how the Trump administration will handle enforcement of the Foreign Corrupt Practices Act (“FCPA”). In the meantime, we...more

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