What happens when an entire era of anti-corruption enforcement is put on pause? Is this a strategic move to bolster American businesses or a dangerous rollback of corporate accountability? In an unprecedented move, the Trump administration has hit the brakes on FCPA enforcement for at least 180 days, citing concerns over U.S. economic competitiveness and national security. In this episode of Corruption, Crime, and Compliance, Michael Volkov breaks down the implications of this game-changing executive order. The executive order claims that FCPA enforcement has been stretched beyond its original intent, harming American businesses while benefiting foreign competitors. With the Department of Justice now ordered to reassess its approach to anti-bribery enforcement, the business and legal communities are left wondering—what happens next? Will companies adjust their compliance strategies, or will global enforcement trends keep them in check?
You'll hear him discuss:
- The Trump administration’s rationale for halting FCPA enforcement and why the decision was both surprising and expected
- The executive order’s directive to the Attorney General to reassess FCPA investigations and enforcement priorities
- The shift in DOJ focus from corporate bribery cases to prosecuting cartels and transnational criminal organizations
- The potential impact on global anti-corruption efforts, as countries like the UK, France, and Brazil continue enforcing their own bribery laws
- The uncertainty surrounding DOJ’s forthcoming guidance and what companies should anticipate in the next 180 days
- The broader implications for corporate compliance programs, risk assessments, and international business strategy
- The historical context of past efforts to reform the FCPA and why similar arguments were made over a decade ago
- The potential for companies to seek remedial measures for past FCPA enforcement actions and the challenges in implementing such a policy
- How this shift in enforcement priorities may affect corporate ethics, internal investigations, and global compliance expectations
Resources
Michael Volkov on LinkedIn | Twitter
The Volkov Law Group
