Cutting Through the Noise: Managing FCPA Compliance Risks under New Enforcement Guidelines

President Trump's Executive Order in February 2025 "pausing" U.S. Foreign Corrupt Practices Act ("FPCA") enforcement was perceived by many as an end to a two-decade enforcement run that had cultivated expectations in the compliance community regarding how the government evaluated corruption risks and what the government expected in terms of risk mitigation.  Although a June 2025 memorandum from Deputy Attorney General Todd Blanche lifted the pause, the accompanying FCPA enforcement guidelines raise a host of questions about how the FCPA will be enforced going forward and-as a result-where and how legal and compliance professionals should dedicate time and resources to compliance.  This program, designed to benefit experienced in-house and external legal and compliance professionals, will discuss the new FCPA enforcement guidelines and what they mean for corporate compliance in the short-, medium-, and long-term.   

Learning Objectives: 

1. Discuss FCPA enforcement priorities of the current administration

2. Examine how those priorities may manifest in practice 

3. Predict emerging FCPA risk areas 

4. Examine how companies can best respond to these risks