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Pausing FCPA: is anti-corruption compliance on pause?

24 February 2025

On 10 February 2025, President Trump signed an executive order, "Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security" ("EO"): Is anti-corruption compliance on pause?

The EO establishes a moratorium on new investigations and enforcement actions under the FCPA for 180 days (with the possibility of a 180-day extension) and directs the Attorney General to review current investigations and enforcement actions within the specified timeframe, along with a revision of the guidelines governing FCPA investigations.