FCPA Executive Order: The Future of U.S. Enforcement

James Koukios spoke to Anti-Corruption Report about potential implications of President Donald Trump’s executive order pausing enforcement of the Foreign Corrupt Practices Act (FCPA). He spoke to the uncertainty surrounding pending FCPA investigations at the Department of Justice (DOJ), guidance around self-reporting during the enforcement suspension, and the potential for enforcement to increase on non-U.S.-based companies.

James said, “Much of the FCPA enforcement playbook was predictable, including, for example, which part of DOJ you were dealing with (the Fraud Section’s FCPA Unit) and which policies applied (such as the Criminal Division’s Corporate Enforcement Policy and the Evaluation of Corporate Compliance Programs). We do not know whether any aspect of that playbook will remain in place after the pause concludes or what, if any, new standards and policies will replace them.”

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