The Continuing Threat of Individual FCPA Enforcement Actions in 2026
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. The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continue to balance FCPA enforcement against other national priorities, and senior officials have issued at times inconsistent public statements regarding enforcement...











