FCPA Enforcement Might Take A Pause – Your Compliance Needs Won't

Corporate compliance officers might feel like they've been put through the whirlwind lately, with the Trump Administration issuing one sweeping announcement about corporate enforcement after another.

Except, remember what a whirlwind does. It spins you round and round, makes you feel dizzy and confused... and then leaves you pretty much right where you were before.

The more we ponder the Administration's moves on corporate compliance, the more that metaphor fits.

Consider the announcements themselves. Most notably, President Trump issued an executive order on February 10 that paused all enforcement of the Foreign Corrupt Practices Act for at least six months and directed Attorney General Pam Bondi to issue new guidelines on all future FCPA enforcement – guidelines that presumably will take a much lighter approach than what we've seen for the last twenty years.