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

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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 at the US Foreign Corrupt Practices Act (FCPA). As echoed in the related fact sheet, the Order pauses Department of Justice (DOJ) enforcement of the FCPA for at least 180 days until DOJ “issues revised FCPA enforcement guidance that promotes American competitiveness and efficient use of federal law enforcement resources.”

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