What actually changed in 2025

In February 2025, an executive order directed the DOJ to pause new FCPA investigations and enforcement for a six-month review. For a few months, that created real uncertainty — some pending matters were dropped, and the foreign-bribery team was reduced.

Then, in June 2025, the DOJ issued new enforcement guidelines that effectively ended the pause. They didn’t switch enforcement off — they re-pointed it. Going forward, the DOJ said it would prioritize conduct connected to US national security and economic competitiveness, cartels and transnational criminal organizations, schemes using shell companies, and bribery involving state-owned enterprises — while spending less energy on routine, low-dollar business courtesies. The guidance also leaned toward pursuing individuals over corporate structures.

And enforcement has continued. The DOJ reached its first corporate FCPA resolution under the new guidelines in late 2025, and individual prosecutions have carried into 2026. The headline “pause” was real; the conclusion that the FCPA went away is not.

Why a narrower DOJ focus is not a green light

A shift in prosecutorial priorities is not a change in the law. The same conduct that was illegal in 2024 is illegal today — and several things make “they probably won’t prosecute this” a dangerous bet to build a program around:

The bigger blind spot: the FCPA isn’t the only law in the room

Here’s the point a lot of the “FCPA is paused” commentary misses entirely: if you operate globally, the DOJ is the only regulator watching you. A company that relaxes its anti-corruption program because the US enforcement has narrowed is reading the wrong dashboard.

The UK Bribery Act is, in several respects, tougher than the FCPA. It generally applies to any organization that carries on business — or part of a business — in the UK, wherever the conduct actually happens. It covers bribery between private companies, not just payments to government officials. It has no exception for the small “facilitation” payments the FCPA narrowly permits. And it includes a corporate “failure to prevent bribery” offense: a company can be on the hook when someone associated with it pays a bribe, unless it can show it had adequate procedures in place — which is to say, a real, working compliance and training program.

It doesn’t stop there. France’s Sapin II law requires larger companies to maintain anti-corruption programs and is enforced by a dedicated agency. Most EU countries, along with dozens of others, criminalize foreign bribery under the OECD Anti-Bribery Convention. These regulators set their own priorities — and they don’t pause because Washington did. In at least one 2025 matter, US authorities closed an inquiry while a related investigation by a European regulator carried on.

For a global company, the practical takeaway is simple: international anti-corruption law is not a backstop to the FCPA — in places, it’s the stricter standard. Ignoring it because US enforcement has softened is exactly the kind of blind spot that leads to an enforcement action elsewhere.

What this means for your anti-corruption training

The smart move isn’t to scale back — it’s to maintain a durable training program that holds up no matter who sets enforcement priorities. A few practical implications:

Frame it as anti-corruption, not just “FCPA.” Training that speaks to the FCPA, the UK Bribery Act, and applicable local laws together is both more accurate for a global workforce and more resilient to US policy swings.

Lean into the current high-risk patterns. The DOJ’s stated priorities — third-party intermediaries, state-owned enterprises, and concealment — are exactly the situations your highest-risk employees face. Train the recognition of those moments specifically.

Don’t forget the books. The FCPA’s accounting provisions — how a payment gets recorded — remain a live area, and one with a longer enforcement clock.

Train the decision, not the statute. Employees almost never set out to pay a bribe — they fail to recognize that a consulting fee, a hospitality invitation, or a vendor gift is one. That recognition is built through realistic scenarios, which is the most enforcement-proof investment you can make.

Train the moment, not the headline

See the anti-corruption and FCPA scenarios your highest-risk employees actually face in the field — built to hold up across regulators and administrations.

Explore the FCPA Scenarios →

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