Our colleagues Isabelle De Smedt and BJ Stieglitz have published an advisory providing additional insights into President Trump’s decision to pause FCPA enforcement, as we previously highlighted here. Among the takeaways:
- The Executive Order does not address SEC, CFTC, or foreign agency anticorruption enforcement.
- The Executive Order will impact existing and past FCPA investigations and enforcement actions.
- Continued vigilance and investment in compliance and internal controls is needed.
