Recent Executive Order Impacting FCPA

On February 10, 2025, President Trump signed an Executive Order (EO)¹ directing the U.S. Attorney General to review the guidelines and policies governing investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA) on the basis that current enforcement of the FCPA impedes U.S. foreign policy objectives.

During the mandated 180-day review period, the EO ordered that:

• The initiation of any new FCPA investigation or enforcement action is ceased, unless the Attorney General determines that an exception should be made;
• All existing FCPA investigations or enforcement actions are to be reviewed by the Attorney General in light of the objectives stated in the EO; and