News & Analysis as of

Trump Administration Anti-Corruption Corporate Governance

Redgrave LLP

Maintaining Information Preservation and Management Vigilance in an Age of Apparent Reduced Law Enforcement

Redgrave LLP on

Corporate legal departments are busy. They face new privacy regulations, ever-shifting trade policies, developments in artificial intelligence, and an unending stream of breaking news. It is difficult to keep up, and lately,...more

NAVEX

DOJ’s New FCPA Guidelines: Key Takeaways for Companies

NAVEX on

On June 9, the U.S. Department of Justice (DOJ) issued the much-anticipated Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (the “FCPA Guidelines” or “Guidelines”) in response to President...more

DLA Piper

DOJ’s Revised Policy on Crediting Fines: Emphasis on Victims

DLA Piper on

Without fanfare, the Department of Justice (DOJ or the Department) has published a memorandum revising its policy on when – and how – it will give credit to companies for fines and other payments made to other agencies,...more

Troutman Pepper Locke

Trump Administration's FCPA Investigations and Enforcement Guidelines

Troutman Pepper Locke on

On June 9, Deputy Attorney General Todd Blanche released a much-anticipated update to the Trump administration’s plans for enforcement of the Foreign Corrupt Practices Act (FCPA)....more

Cooley LLP

DOJ Resumes Foreign Bribery Investigations, Focusing on ‘Vindication of US Interests’

Cooley LLP on

On June 9, 2025, the Department of Justice (DOJ) issued new guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (FCPA), following a four-month pause of new FCPA investigations per President...more

Thomas Fox - Compliance Evangelist

Compliance into the Weeds: Leaving on a (Qatari) Jet Plane

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

NAVEX

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

NAVEX on

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

Husch Blackwell LLP on

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

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

Husch Blackwell LLP

New Executive Order Directs DOJ to Pause FCPA Enforcement

Husch Blackwell LLP on

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

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

Herbert Smith Freehills Kramer

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

Morgan Lewis on

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

Wiley Rein LLP on

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

Paul Hastings LLP on

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

Lowenstein Sandler LLP

Long Live the FCPA?

Lowenstein Sandler LLP on

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

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

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)

The Volkov Law Group on

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

Akin Gump Strauss Hauer & Feld LLP

Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security (Trump EO Tracker)

Orders the Attorney General to review in detail all existing Foreign Corrupt Practices Act (FCPA) investigations or enforcement actions and take appropriate action with respect to such matters to restore proper bounds on FCPA...more

The Volkov Law Group

FCPA Predictions: Don’t Expect Much to Change

The Volkov Law Group on

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

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