On February 10, 2025, President Trump issued an Executive Order directing the Attorney General to pause Foreign Corrupt Practices Act (FCPA) investigations and prosecutions pending the review of all FCPA guidelines and past and existing FCPA investigations and actions. Following this 180-day review period, the Attorney General is directed to issue revised FCPA enforcement guidance that will govern all future or existing FCPA investigations and prosecutions. These revised guidelines will require the Attorney General to “specifically authorize” future FCPA investigations and prosecutions. The Executive Order requires the Attorney General to determine if any “remedial measures” are warranted to address “inappropriate past FCPA” actions.
View other S&C insights relating to President Trump’s recent executive orders.