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ARTICLE · 20 FEBRUARY 2025

Executive Order Suspending Foreign Corrupt Practices Act Enforcement Signals New Enforcement Priorities

Duane Morris LLP
Duane Morris LLP
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On February 10, 2025, President Donald Trump issued an executive order titled "Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security."

United StatesCriminal Law
Michael J. Rinaldi
Michael J. Rinaldi
William M. McSwain
William M. McSwain
Mary P. Hansen
Mary P. Hansen
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As a result, for a period of 180 days, the order requires the attorney general to review guidelines and polices that previously directed investigations and enforcement under the FCPA.

On February 10, 2025, President Donald Trump issued an executive order titled "Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security." The order suspends enforcement of the Foreign Corrupt Practices Act (FCPA) for a period of 180 days, during which time the U.S. attorney general will seek to align FCPA enforcement with the Trump administration's twin aims of enhancing national security and restoring competitive balance in the global economy for American companies. The executive order portends a shift in FCPA enforcement priorities, especially when considered alongside other recent activity, such as the February 5 memorandum by Attorney General Pam Bondi regarding "Total Elimination of Cartels and Transnational Criminal Organizations."

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Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.

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