In an executive order issued on February 13, President Trump ordered the Department of Justice (DOJ) to place a six-month “pause” on enforcement of the Foreign Corrupt Practices Act (FCPA). During the pause, Attorney General Bondi will cease any new FCPA investigations unless her office grants an individual exception.

Nicole Sprinzen, vice chair of Cozen O’Connor’s White Collar Defense and Investigations practice, predicts that this enforcement pause “is unlikely to be the death knell of the FCPA".

"Even if the FCPA is not being enforced, there are other U.S. laws that can be used to prosecute foreign bribery offenses," she said. Foreign bribery laws in other countries also remain unaffected. “Companies operating internationally should continue to focus on compliance” with the U.S. and foreign anti-bribery laws, “and not just because getting business through bribes is generally seen as ethically wrong,” Nicole said. In addition, she noted, any statute of limitations for FCPA violations would extend back more than four years, when a new presidential administration may focus on FCPA enforcement once again.

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