A Survey Of Recent Enforcement Actions, Trends & Priorities

The landscape of criminal prosecution of foreign bribery has shifted, and the second Trump administration has made its priorities clear; however, companies still have 950 million reasons and counting to strengthen their compliance frameworks when dealing with government contracts and/or government officials—specifically foreign government officials. RTX Corporation's recent $950 million settlement highlights the need for companies to be aware of the current Foreign Corrupt Practices Act ("FCPA") and the False Claims Act of 1863 ("FCA") cases, enforcement trends, considerations, and recommendations to mitigate or avoid penalties and associated reputational harm for FCPA and FCA violations. This client bulletin provides an overview of RTX Corporation's $950 million settlement, other notable FCPA/FCA cases, trends and enforcement priorities, and outlines the recommendations that individuals and companies can take to adhee to the FCPA/FCA, strengthen compliance, mitigate