The final quarter of 2025 produced a modest resurgence in Foreign Corrupt Practices Act (FCPA) activity following the administration’s June 2025 FCPA guidelines. Whether that uptick signals a sustained enforcement trend remains uncertain.

But one theme remains clear: individual FCPA enforcement is alive and well.

While corporate resolutions may benefit from evolving DOJ policy and a renewed emphasis on negotiated dispositions, individuals continue to face indictment, trial, sentencing, forfeiture, and reputational destruction.