Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 14 FEBRUARY 2025

Trump's FCPA Enforcement 'Pause': Considerations And Potential Implications

Greenberg Traurig
Greenberg Traurig
Contributor
Greenberg Traurig

Greenberg Traurig

Greenberg Traurig, LLP has approximately 3,200 lawyers across 51 locations in the United States,...

View firm profile
Explore more from Greenberg Traurig

On Feb. 10, 2025, President Trump signed an executive order regarding FCPA enforcement.

United StatesCriminal Law
Cuneyt Akay
Cuneyt Akay
Tyler D. Coombe
Tyler D. Coombe
Kara Bombach
Kara Bombach
Matthew J. Cannon
Matthew J. Cannon
Tracy S. Combs
Tracy S. Combs
Bruno Cova
Bruno Cova
Jared Dwyer
Jared Dwyer
Adam Hoffinger
Adam Hoffinger
Michael X. Marinelli
Michael X. Marinelli
+1 more

On Feb. 10, 2025, President Trump signed an executive order regarding FCPA enforcement.1 The executive order:

  • pauses enforcement of current FCPA actions and ceases initiation of new actions (absent exceptions made by the Attorney General) for at least 180 days;
  • directs the Attorney General to review past and existing FCPA actions; and
  • directs the Attorney General to issue new guidance on future FCPA enforcement actions.

While we await the Attorney General's new FCPA enforcement guidance, this GT Alert provides considerations regarding anti-corruption enforcement and compliance.

  1. The FCPA is still the law. Despite the executive order, the FCPA is still the law of the land. The FCPA was enacted 48 years ago by Congress and nothing in the executive order changes the law. Companies should continue to implement and maintain effective compliance programs.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

DOJ Announces 2026 National Health Care Fraud Takedown: 455 Defendants Charged In $6.5 Billion Enforcement Action

The Department of Justice's 2026 National Health Care Fraud Takedown charged 455 defendants in connection with $6.5 billion in alleged fraud schemes, marking an unprecedented scale of enforcement action. This whole-of-government approach leverages advanced data analytics and international cooperation to combat healthcare fraud across Medicare, Medicaid, and other federal programs. The enforcement action demonstrates heightened scrutiny of providers, aggressive asset forfeiture, and a focus on cases involvin
United StatesCriminal Law
Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP
Article

Prediction Markets — Legitimate Trading Or Gambling?

The rapid expansion of online prediction markets has created a regulatory gray area where consumers can effectively wager on sporting events even in states that prohibit traditional sports betting. As platforms like Kalshi, Polymarket, and Robinhood argue their services constitute futures trading rather than gambling, state attorneys general and the CFTC are locked in legal battles over jurisdiction and consumer protection.
United StatesCriminal Law
Klemchuk
Klemchuk
Article

2026 Mid-Year Update On DOJ Corporate And White Collar Enforcement

The Department of Justice has implemented its first-ever Department-wide Corporate Enforcement Policy, fundamentally reshaping how companies navigate voluntary self-disclosure, cooperation, and remediation across all criminal matters. This comprehensive mid-year analysis examines the new three-path framework, explores critical enforcement developments in FCPA, export controls, trade fraud, and healthcare, and reveals how recent resolutions signal both opportunities and heightened risks for corporate complia
United StatesCriminal Law
Sher Tremonte
Sher Tremonte
Article

October 2026 Visa Bulletin Advances EB-5 Filing Date For Mainland China By 4 Years

The U.S. Department of State has released the October 2026 Visa Bulletin, marking the start of fiscal year 2027 with significant changes to employment-based immigrant visa categories. How will the advancement of priority dates, particularly the substantial four-year leap for mainland China-born EB-5 investors in the Dates for Filing chart, impact eligible applicants seeking adjustment of status benefits?
GlobalImmigration
Greenberg Traurig
Greenberg Traurig
Article

DHS Continues Work Authorization For Ukrainian, Sudanese TPS Beneficiaries; I-9 Guidance Remains Unclear

The Department of Homeland Security has not issued formal determinations for Temporary Protected Status designations for Ukraine and Sudan despite the October 19, 2026 expiration date, creating uncertainty for employers navigating Form I-9 compliance and employment authorization documentation. USCIS states that affected individuals retain TPS protections and work authorization, but has not updated operational guidance to explain how employers should document continued employment eligibility or handle
United StatesImmigration
Greenberg Traurig
Greenberg Traurig
Article

Department Of State Announces Compliance With Court Order Ending Diversity Visa Issuance Pause

Following a federal court order in Medani v. Trump, the U.S. Department of State has resumed issuing Diversity Immigrant Visas after a nine-month pause that began in December 2025. DV-2026 selectees now face a critical deadline of September 30, 2026, to complete their visa processing or permanently lose their opportunity for permanent residence through the diversity visa lottery program.
United StatesImmigration
Greenberg Traurig
Greenberg Traurig
Article

FTC Asks Whether Platform Ad Tools Fuel Impersonation Scams

The Federal Trade Commission is exploring whether digital platforms should bear greater responsibility for preventing impersonation ads that falsely pose as legitimate businesses or government agencies. Through an Advance Notice of Proposed Rulemaking, the agency seeks public input on potential amendments to its existing Impersonation Rule, examining how ad-optimization tools and platform practices...
United StatesConsumer Protection
Greenberg Traurig
Greenberg Traurig
Article

Deepfakes, Chatbots, AI-Generated Text: European Commission Details Transparency Obligations Under The AI Act

The European Commission has published draft guidelines interpreting the AI Act's transparency obligations, establishing when and how organizations must disclose AI-generated content, deepfakes, and automated interactions. These guidelines clarify that deepfake labeling applies regardless of intent to deceive, that AI systems must identify themselves at the point of interaction, and that the editorial review exception for AI-generated text requires substantive human oversight with clear accountability.
European UnionTechnology
Greenberg Traurig
Greenberg Traurig
Article

November 2026 Visa Bulletin: Key Updates And Priority Date Movement

The U.S. Department of State's November 2026 Visa Bulletin brings forward movement in several family-sponsored and employment-based immigrant visa categories, with significant advances for certain countries and preference levels. USCIS has confirmed that applicants in all preference categories may use the Dates for Filing chart to determine eligibility for adjustment of status applications, potentially allowing earlier filing for those whose priority dates fall before the applicable cut-off dates.
United StatesImmigration
Greenberg Traurig
Greenberg Traurig
Article

State Department Updates Diversity, Immigrant Visa Processing Following Federal Court Decisions

Following two federal court decisions, the U.S. Department of State has lifted categorical pauses on immigrant visa issuance for nationals of 75 countries and diversity visa processing for DV-2026 selectees. While these policy changes allow cases to proceed through ordinary adjudication, they do not guarantee visa approval or admission, and timing remains critical as diversity visa eligibility expires September 30, 2026.
United StatesImmigration
Greenberg Traurig
Greenberg Traurig
Article

BIOSECURE Act Update: Court Enjoins WuXi AppTec’s 1260H Designation, but Strategic and Compliance Clocks Keep Running

The U.S. District Court for the District of Columbia has preliminarily enjoined the Department of War from enforcing WuXi AppTec's Section 1260H designation, finding the agency misread its evidence on state and military affiliation. However, this ruling does not close alternative pathways to biotechnology company of concern (BCC) designation under the BIOSECURE Act, and earlier supply-chain restrictions continue to drive near-term compliance decisions with a critical June 30, 2027 deadline for sub-tier supp
United StatesGovernment, Public Sector
Greenberg Traurig
Greenberg Traurig
Article

Court Postpones DHS Fixed-Term Admission Rule For F, J, And I Nonimmigrants

A federal court has postponed the Department of Homeland Security's fixed-term admission rule for F, J, and I nonimmigrants, preserving the duration of status framework and blocking requirements that would have imposed four-year caps on international students and exchange visitors. The ruling addresses concerns about arbitrary rulemaking, inadequate cost analysis, and potential disruption to U.S. educational institutions and their international programs.
United StatesImmigration
Greenberg Traurig
Greenberg Traurig