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ARTICLE · 17 FEBRUARY 2025

FCPA Enforcement On Pause Per Executive Order

Holland & Knight
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Just over two months ago, the Kansas City Chiefs were still two-time defending Super Bowl champions, Luka Doncic was a Dallas Maverick, and the U.S. Department of Justice's...

United StatesCriminal Law
Cary Aronovitz
Cary Aronovitz
Eddie A. Jauregui
Eddie A. Jauregui
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Just over two months ago, the Kansas City Chiefs were still two-time defending Super Bowl champions, Luka Doncic was a Dallas Maverick, and the U.S. Department of Justice's (DOJ) Foreign Corrupt Practices Act (FCPA) Unit was lauded as the "Department's foremost experts in corporate enforcement, compliance, and policy" that had unraveled "the most complex corporate corruption and fraud schemes that reach across the Globe." Indeed, as late as Dec. 5, 2024, the DOJ applauded its FCPA enforcement unit whose prosecutions had resulted in billions of dollars in fines and penalties sent back to U.S. coffers.

The DOJ reiterated that 2024 was a "Banner Year" for FCPA enforcement.

Times Have Changed

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