In a significant move signaling Europe’s growing autonomy in global anti-corruption enforcement, prosecutors from the United Kingdom, France, and Switzerland have formed a new cross-border alliance: the International Anti-Corruption Prosecutorial Taskforce. Announced on March 20, 2025 by the U.K.’s Serious Fraud Office (SFO), the taskforce is designed to deepen cooperation among these three countries on bribery and corruption investigations—at a time when the Trump Administration is reshaping the United States’ approach.
As has been widely reported, the White House issued an Executive Order[1] in February 2025 temporarily halting new investigations under the Foreign Corrupt Practices Act (FCPA). In addition to the 180-day pause, the Executive Order directed U.S. Attorney General Pam Bondi to reevaluate all pending FCPA cases and reshape the Department of Justice’s (DOJ) policies regarding future enforcement. Many open questions remain during this in-flux period, including if DOJ will prioritize cases against foreign nationals and companies, and if it will enforce another tool to curb foreign corruption, the Foreign Extortion Prevention Act (FEPA). One datapoint occurred on April 2, 2025, when on the eve of trial in the District of New Jersey, DOJ moved to dismiss a years-old FCPA case against two former executives of U.S.-based Cognizant Technology Solutions Corp. involving allegations of bribery in India. In this climate, the European agencies comprising the taskforce appear to be preparing to fill any enforcement gaps, stating in the announcement that they will “stand firm” in their commitment to confront international bribery and corruption.
A New Center of Gravity in Anti-Corruption Enforcement
Historically, U.S. authorities have been the global leaders in prosecuting corporate bribery, leveraging the FCPA’s broad jurisdiction and pursuing multi-billion-dollar settlements with companies around the world. For example, according to the Organization for Economic Co-operation and Development (OECD), from 1999 through 2020, the U.S. government obtained 277 FCPA-related criminal convictions, whereas the U.K., France, and Switzerland together had only 113 convictions for foreign bribery. But the United States’ leadership has also included deep partnerships with enforcement agencies in Europe, particularly the U.K.’s SFO, and the Swiss Office of the Attorney General (OAG). Now, those European agencies appear ready to take the lead.
The new taskforce includes a strategic “Leaders’ Group” to align enforcement priorities, and a “Working Group” charged with identifying opportunities for joint action on investigations. The taskforce’s Founding Statement emphasizes information-sharing, best practices, and operational collaboration—including the potential use of Joint Investigative Teams (JITs) to coordinate real-time evidence gathering across borders. The group is also open to expanding its membership, suggesting that other jurisdictions could soon join.
Compliance Isn’t Optional—Even if U.S. Enforcement Slows
For multinational companies, this shift reinforces a critical message: anti-bribery compliance cannot be paused simply because U.S. enforcement is in a state of transition.[2] The U.K. Bribery Act, France’s Sapin II, and Swiss anti-corruption laws all carry significant penalties for bribery, and each country has broad jurisdiction to prosecute foreign companies operating or headquartered in their territory.
Importantly, these laws are not carbon copies of the FCPA and some penalize conduct that would not fall within scope of the FCPA. For example:
- The U.K. Bribery Act criminalizes both commercial and public bribery. It also includes a strict liability offense for companies that fail to prevent bribery committed by persons who perform services for or on behalf of the company. The strict liability provision can be used against companies that operate in the U.K., even if the person who committed the bribery was outside the U.K.
- France’s Sapin II law emphasizes corporate accountability including by requiring large companies (with 500 or more employees) to institute mandatory compliance programs.
- Switzerland’s legal framework includes enforcement against both those who pay bribes and those who accept them. The OAG has also shown increased interest in cross-border financial crime in recent years.
Like prior U.S. administrations that aggressively enforced the FCPA, these countries have each embraced a framework that rewards effective compliance. Demonstrating that a company has robust procedures in place—such as risk assessments, third-party due diligence, internal reporting mechanisms, and ongoing training—can reduce or even eliminate exposure and play a crucial role in settlement negotiations.
Key Takeaways for Companies
- Companies that operate internationally should not limit their anti-bribery compliance efforts. European authorities appear to be filling the gap left by the pause in FCPA enforcement. Companies that scale back compliance efforts risk becoming easy targets for cross-border investigations.
- Expect more multi-agency investigations. Increased use of taskforces and JITs means that misconduct discovered in one country could quickly become the basis for enforcement elsewhere.
- Tailor your compliance program to multiple regimes. One-size-fits-all compliance may not satisfy the requirements of U.K., French, or Swiss authorities. Programs should be evaluated and adapted accordingly.
- Stay alert to future developments in the U.S. The Order pausing FCPA enforcement is a policy decision that may be rescinded by this or a subsequent administration and the FCPA is still a valid law. Further, the pause does not fully foreclose the possibility that an FCPA investigation can be initiated and carried through to an enforcement action, so long as it is approved by the Attorney General. In addition, misconduct which occurs during the current presidential administration may be prosecuted during the next administration.
Final Thought
Criminal enforcement of the FCPA by DOJ is only one risk of committing bribery abroad, and the global anti-corruption landscape is shifting. Companies with international footprints should treat the new European taskforce not as a regional issue, but as a signal that prosecutors are still watching, and collaboration across borders is continuing.
[1] See “Major Shift on Foreign Corrupt Practices Act: Trump Signs EO Pausing Enforcement,” Subject to Inquiry Blog by McGuireWoods (Feb. 11, 2025).
[2] See “Practical Tips for Companies Following President Trump’s Pause on FCPA Enforcement,” Subject to Inquiry Blog by McGuireWoods (Feb. 14, 2025).