The FCPA Executive Order: Historical Context and Corporate Implications

President Trump issued an Executive Order on February 10, 2025, directing a comprehensive review of Foreign Corrupt Practices Act enforcement guidelines and policies for a period of 180 days, and suspending the initiation of new FCPA investigation and enforcement proceedings during this period. However, businesses engaged in transnational commercial activities should continue implementing effective compliance protocols. Understanding the FCPA EO’s precise scope is essential for proper risk assessment and compliance strategy formulation during this period of regulatory reassessment.

Julie Gutiérrez - CTBL Fellow