February 11, 2025 •
Executive Order Pauses Enforcement for FCPA

On February 10, President Donald J. Trump signed an Executive Order pausing enforcement of the Foreign Corrupt Practices Act (FCPA).
The FCPA is a federal law aimed at preventing the bribery of governmental officials of foreign nations by individuals and entities under the jurisdiction of the United States. The act is unique because its goal is not to curtail unethical and illegal behavior of U.S. governmental officials, but to govern the ethical and legal behavior of corporations and individuals doing business overseas.
In his Executive Order, President Trump states the reason for the pause is “FCPA enforcement impedes the United States’ foreign policy objectives and therefore implicates the President’s Article II authority over foreign affairs.” The order states there is “overexpansive and unpredictable” enforcement “for routine business practices in other nations.”
The order requires the U.S. Attorney General to cease initiating new investigations unless they are determined necessary. It also calls for a review by the Attorney General of current FCPA guidelines and policies within the next 180 days, with new guidelines and policies issued if the Attorney General sees fit.
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