On February 10, 2025, President Donald Trump ordered a pause in the enforcement of the FCPA. The pause was introduced by an Executive Order – 14209, which mandated a temporary suspension of all new FCPA investigations and enforcement actions. The stated objective was to ensure that the statute was not being applied in a manner that compromised U.S. economic competitiveness or extended beyond its intended scope, particularly in relation to routine business practices conducted in other foreign jurisdictions. The move prompted significant debate across the global compliance industry, raising questions about the future of international anti-corruption efforts and the potential impact on multinational businesses operating in other jurisdictions.
Following this suspension, the U.S. Department of Justice (DOJ) on 9th June 2025, issued new guidelines announcingthe formal resumption of enforcement activities under theFCPA. The updated enforcement guidelines reflect a strategic realignment in the DOJ’s approach to FCPA enforcement, one that narrows its focus to conduct that poses a demonstrable threat to U.S. national security, foreign policy, and economic competitiveness.
Open PDF to continue reading >>>