Ann Sultan and James Tillen will present the PLI webinar, "FCPA Enforcement Pause: Proceed With Caution," on May 6, 2025. 

Recent actions by the Trump administration represent the most significant changes to enforcement of the Foreign Corrupt Practices Act (FCPA) in the last few decades. However, while the administration has "paused" FCPA enforcement, the FCPA itself is still in effect. What does this mean for companies operating internationally? And what are the practical effects of these changes for companies, especially amidst an international anti-corruption landscape that has evolved substantially beyond a sole focus on FCPA enforcement? There continue to be compelling reasons for companies to take appropriate steps to manage ongoing corruption and related risks, including the business benefits of strong compliance, the prospect of non-U.S. authorities moving to increase their enforcement activity, and a statute of limitations period that will run past the current administration. In addition, DOJ’s focus on enforcement targeting cartels and Transnational Criminal Organizations (TCOs) poses new operational, legal, and compliance risks for corporations operating in cartel and TCO-controlled areas. Certain matters resolved in the last few years are an important indication of the overlap between the FCPA and other regulatory regimes, including trade-related laws and regulations.