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Podcast: Corruption Crime & Compliance
Episode: Episode 394 -- FCPA Enforcement in 2025: A Slowdown, a Policy Reset, and What the Numbers Really Mean
Description: 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...