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ARTICLE · 22 JANUARY 2026

Global Anti-Corruption Insights: Winter 2026

Arnold & Porter
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Although President Trump temporarily paused enforcement of the U.S. Foreign Corrupt Practices Act (FCPA) in the first half of 2025...

GlobalCriminal Law
Marcus Asner
Marcus Asner
Daniel Bernstein
Daniel Bernstein
Caroline Dorsey
Caroline Dorsey
Soo-Mi Rhee
Soo-Mi Rhee
John Tan
John Tan
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Although President Trump temporarily paused enforcement of the U.S. Foreign Corrupt Practices Act (FCPA) in the first half of 2025, U.S. Department of Justice (DOJ) officials recently have declared that enforcement of the FCPA — and other criminal laws that apply to international business conduct — remains alive and well.

In the second half of 2025, two companies negotiated agreements with DOJ to resolve FCPA investigations, and a third came under indictment. DOJ also took to trial two FCPA cases against individuals, winning both. Other individual prosecutions moved forward as well. Criminal FCPA enforcement was therefore down but not out in 2025.

All has been quieter on the civil front, however. The U.S. Securities and Exchange Commission (SEC) did not bring any new FCPA cases this past year, and the future of its specialized "FCPA Unit" hangs in the balance.

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