The Future of Anti-Corruption Enforcement: Potentially Increasing State and Non-US Prosecutions as an Alternative to the FCPA

On February 10, 2025, President Donald Trump signed an executive order instructing the United States Department of Justice (“DOJ”) to pause enforcement of the Foreign Corrupt Practices Act (“FCPA”) for a period of 180 days. The order requires the United States Attorney General to review all existing FCPA investigations, and to issue updated guidelines or policies, as appropriate, for enforcing the statute that adequately promotes the President’s “authority to conduct foreign affairs and...
By: Mayer Brown

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