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ARTICLE · 18 JUNE 2025

Updated FCPA Guidance

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Shortly after taking office President Trump signed an executive order titled, "Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security."

United StatesCriminal Law
Katten Muchin Rosenman LLP
Katten Muchin Rosenman LLP
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Shortly after taking office President Trump signed an executive order titled, "Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security." Among other things, President Trump instructed that the FCPA should not be "stretched beyond proper bounds and abused in a manner that harms the interests of the United States" or enforced in a way that compromises "American economic competitiveness and . . . national security." He further directed the Department of Justice (DOJ) to issue updated FCPA guidance. Earlier this week, the DOJ released that guidance in a memo, titled "Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act" (Guidelines).

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