FCPA enforcement in 2025 was defined by what did not happen as much as what did. Compared to prior years, the number of publicly announced cases declined sharply, corporate resolutions were fewer, and the overall enforcement posture appeared more restrained. This slowdown, however, reflects a policy recalibration—not a dismantling—of the FCPA enforcement regime.

Early in the year, DOJ paused FCPA enforcement activity while it reviewed policy priorities. That pause, followed by the issuance of revised enforcement guidance mid-year, produced a measurable decline in announced actions. Several investigations slowed, at least one long-running prosecution was dismissed, and the SEC brought no new FCPA cases during the year.

DOJ’s revised guidance emphasized selectivity, signaling that enforcement would focus on higher-impact cases—large bribe payments, clear evidence of corrupt intent, sophisticated concealment, and conduct implicating U.S. national security or competitiveness. Lower-value cases and routine “business courtesy” fact patterns were explicitly deprioritized.

The public numbers reflect that shift. 2025 was one of the lightest FCPA enforcement years in more than a decade. DOJ announced only a small handful of corporate outcomes, while continuing to emphasize voluntary self-disclosure and cooperation through declinations and deferred prosecution agreements.

Two points, however, deserve emphasis.

First, serious cases still produced serious outcomes. DOJ resolved a significant bribery investigation involving a telecommunications company through a deferred prosecution agreement exceeding $100 million. DOJ also issued a declination with disgorgement to Liberty Mutual, crediting voluntary disclosure, cooperation, and remediation—reinforcing that the Corporate Enforcement Policy remains intact.

Second, enforcement infrastructure did not disappear. Investigative teams, international cooperation channels, whistleblower pipelines, and accounting control authorities remain fully operational. The slowdown reflects prioritization, not retreat.

The correct takeaway from 2025 is not that FCPA enforcement is “over,” but that the bar for cases has been raised. Fewer matters are being brought, but those that do move forward will likely involve stronger evidence, clearer intent, and more aggressive theories.