I’ve already been asked about Foreign Corrupt Practices Act enforcement during a second Trump administration.
My response is generally the same as when I was asked similar questions during the time frame 2016-2020.
See here “Let’s All Take A Deep Breath When It Comes To FCPA Enforcement In The Trump Administration.” (Nov. 2016)
See here “Let’s All Take A Deep Breath, Gaps In FCPA Enforcement Are Common.” (May 2017).
See here “It’s Time Again To Take A Deep Breath.” (Jan. 2020).
See here “Corporate FCPA Enforcement In 2023 Compared To Prior Years” (documenting corporate FCPA enforcement yearly numbers 2007-2023), here “A Focus On DOJ Individual FCPA Enforcement Actions” (documenting DOJ individual FCPA enforcement yearly numbers 2000-2023), and here “A Focus on SEC Individual Actions” (documenting SEC individual FCPA enforcement yearly numbers 2000-2023). As the numbers from 2017-2021 demonstrate, FCPA enforcement (across various categories) was at or above historical averages during the first Trump administration (and in some cases set records).
Eight years ago this week, some FCPA commentators had “come aparts” (and substantially lost credibility). Hopefully, this does not happen again.
