Overview
Steptoe partners Iris Bennett and Claire Rajan authored an article that appeared in The Compliance and Ethics Blog, "Perspective on the Executive Order on FCPA Enforcement." The article discusses the implications of President Trump’s February 2025 Executive Order to pause Foreign Corrupt Practices Act (FCPA) enforcement for six months, asserting that the statute has been systematically overexpansive and harms American economic competitiveness and national security. While DOJ enforcement may become less predictable and rare in the short term, other authorities and bodies can still initiate investigations, including the SEC, Congress, states attorneys general, and foreign regulators. Companies must maintain robust compliance programs to mitigate legal and reputational risks, as future administrations may still enforce the FCPA.
