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Executive Orders Corporate Governance Anti-Corruption

Bass, Berry & Sims PLC

Is the “Pause” Over? DOJ Resumes FCPA Enforcement, Announces Guidelines

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On June 9, Deputy Attorney General Todd Blanche issued a memorandum entitled Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (the Memo) addressed to the head of the Criminal Division of the...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

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

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

TransPerfect Legal

Rethinking Risk: Insights from FCPA Houston 2025

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Top compliance professionals, legal experts, and enforcement officials gathered to explore the evolving anti-corruption landscape during the American Conference Institute (ACI)’s 18th Forum on the Foreign Corrupt Practices...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

Maynard Nexsen

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

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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

NAVEX

FCPA Enforcement Might Take a Pause – Your Compliance Needs Won’t

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Corporate compliance officers might feel like they’ve been put through the whirlwind lately, with the Trump Administration issuing one sweeping announcement about corporate enforcement after another. Except, remember what a...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

Foley & Lardner LLP

Business Impacts of Trump’s Executive Order Pausing FCPA Enforcement

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On February 10 President Trump issued an Executive Order, Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security, signaling a shift in U.S. enforcement priorities regarding...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

Brownstein Hyatt Farber Schreck

New Executive Order on FCPA: Impact on Corporate Compliance

On Feb. 10, the White House announced a new executive order (“EO”) entitled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.” This EO essentially directs the U.S....more

McGuireWoods LLP

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

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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

Wilson Sonsini Goodrich & Rosati

Executive Order Temporarily Pauses DOJ's FCPA Enforcement and Orders a Review of Guidelines and Policies

On February 10, 2025, President Trump signed an executive order pausing enforcement of the Foreign Corrupt Practices Act (FCPA), a law that prohibits companies with a connection to the United States from bribing foreign...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

Baker Botts L.L.P.

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

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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

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

Morrison & Foerster LLP

FCPA Enforcement Under the Second Trump Administration

Since its enactment in 1977, the FCPA has been the primary legal mechanism in the United States for preventing and punishing corrupt business practices around the world. At a high-level, the FCPA applies to both domestic and...more

The Volkov Law Group

Taking Stock of the FCPA Fallout (Part III of V)

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What an amazing turn of events? — Who would have predicted that the Trump Administration would take such a bold action in the name of advancing “American Competitiveness.” I admit I did not see this coming — the Trump...more

Kohrman Jackson & Krantz LLP

Client Alert: Executive Order Suspends Enforcement of Foreign Bribery Law

On February 10, 2025, President Donald J. Trump signed an Executive Order pausing enforcement actions under the Foreign Corrupt Practices Act (FCPA), citing concerns that excessive enforcement was harming American businesses...more

Dorsey & Whitney LLP

Should Your Company Shut Down Its Anti-Corruption Compliance Program and Start Paying Bribes? Here Are a Few Reasons to Think...

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On February 10, 2025, President Trump issued a new Executive Order (“EO”) titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” This EO comes on the tail of Attorney...more

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