In October, WLG's Compliance & Investigations Group held
a frank, cross-border check-in to discuss the current state of
compliance. The agenda was simple – enforcement trends and
the current state of preventive measures – but the discussion
quickly revealed a more complex picture: less budget, fewer
"classic" Foreign Corrupt Practices Act (FCPA)-style
mandates, but a broader and more political enforcement landscape in
which compliance is deeply entangled with ESG, financing, and
access to markets.
A first theme was quiet retrenchment . Several participants
reported a noticeable slowdown in preventive compliance work and
extensive internal investigations, particularly those historically
driven by U.S. FCPA risk. In Germany, there has been hesitation
among small and mid-sized companies to invest in comprehensive
compliance management systems, as the legal value is uncertain and
economic conditions are challenging. In China, there has been a
noticeable decline in FCPA
