Trump Administration's FCPA Enforcement Pause Spurs State Actions; WilmerHale Urges Defense Firms to Maintain Compliance

Legal experts and law firms have highlighted concerns regarding the Trump administration's recent pause in federal enforcement of the Foreign Corrupt Practices Act (FCPA). While the federal government appears to be scaling back its securities enforcement efforts, state attorneys general are expected to increase their foreign anti-corruption enforcement activities, potentially creating a more complex and fragmented regulatory environment. Commentary from WilmerHale attorneys Paul Connell, Swain Wood, and Ben Neaderland suggests that this shift will result in enforcement being policed more heavily at the state level. Additionally, experts emphasize that defense firms should not interpret the federal pause as a relaxation of anti-bribery laws, urging continued compliance with FCPA requirements. This evolving enforcement landscape has been analyzed by various legal authorities and firms, including Miller Canfield, WilmerHale, and Husch Blackwell, reflecting concerns about the implications for companies operating internationally.