In February 2025, President Donald Trump issued an executive order pausing the enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days, citing concerns that its application was overly expansive and detrimental to U.S. economic competitiveness and national security. The order directs Attorney General Pam Bondi to review existing FCPA guidelines and develop new policies that align with the administration's objectives. White House

This suspension has raised significant concerns among anti-corruption advocates and legal experts. The FCPA, enacted in 1977, has been a cornerstone of global anti-corruption efforts, holding companies accountable for bribing foreign officials to secure business advantages. Critics argue that halting its enforcement could undermine decades of progress in combating international corruption and potentially embolden unethical business practices. The Guardian

While the executive order affects criminal prosecutions under the FCPA, the law itself remains in effect, as only Congress has the authority to repeal it. The Securities and Exchange Commission (SEC), responsible for civil enforcement of the FCPA, has not announced any changes to its enforcement policies, leading to uncertainty about the future landscape of anti-corruption enforcement in the U.S. Duane Morris

The long-term implications of this suspension are yet to be fully understood. Businesses are advised to maintain robust compliance programs, as future administrations may reinstate rigorous enforcement, and violations could still be subject to prosecution under other statutes or in other jurisdictions. Additionally, international anti-bribery laws remain in force, and companies operating globally must navigate a complex legal environment to avoid potential liabilities. troutman pepper locke