Tagged: Executive Order Pause

New FCPA Guidance — What to Expect (Part IV of V)

As we continue through the maze of Executive Orders and new Guidance, which is expected in 180 days, the questions surrounding FCPA enforcement are swirling.  In some respects, we have had a preview.  It is hard to know what will happen beyond some basic points. Let’s start with last week’s memo issued by Attorney General Bondi, which was entitled — Total Elimination of Cartels and...

Taking Stock of the FCPA Fallout (Part III of V)

What an amazing turn of events? — Who would have predicted that the Trump Administration would take such a bold action in the name of advancing “American Competitiveness.” I admit I did not see this coming — the Trump Administration during the first term had an aggressive record of FCPA enforcement. We all expected that to continue. Boardrooms, C-Suites and Legal/Compliance professionals are stunned.  How...