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ARTICLE · 12 FEBRUARY 2025

Analyzing The Attorney General's FCPA Enforcement Shift

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The Foreign Corrupt Practices Act (FCPA), enacted in 1977 after the Watergate scandal, was designed to combat international corruption and corporate bribery.

United StatesAntitrust/Competition Law
Gerald M. Moody Jr.
Gerald M. Moody Jr.
Samuel W. Salyer
Samuel W. Salyer
Samantha Jennifer Block
Samantha Jennifer Block
Stephanie Ondrof
Stephanie Ondrof
James J. Benjamin Jr.
James J. Benjamin Jr.
Michael Asaro
Michael Asaro
Charles F. Connolly
Charles F. Connolly
Katherine Rachel Goldstein
Katherine Rachel Goldstein
Parvin Daphne Moyne
Parvin Daphne Moyne
+9 more
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UPDATE: President Signs Executive Order Directing DOJ to Pause All FCPA Enforcement for 180 Days

On February 10, 2025, President Trump issued an Executive Order directing the U.S. Department of Justice (DOJ) to pause all enforcement of the Foreign Corrupt Practices Act (FCPA). The Executive Order, titled "Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security," instructs the Attorney General to (i) pause FCPA enforcement for 180 days; (ii) issue updated guidelines or policies governing FCPA investigations or enforcement actions; and (iii) review and take appropriate action regarding ongoing and past FCPA investigations and enforcement actions. The Executive Order states that the President's foreign affairs authority, American economic competitiveness and U.S. national security are impacted by "overexpansive and unpredictable FCPA enforcement against American citizens and businesses . . . for routine business practices

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