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    May 7, 2025

The International Anti-Corruption Taskforce and U.S. FCPA Enforcement: A Look Ahead

On March 20, 2025, the UK’s SFO, France’s Parquet National Financier and the Office of the Attorney General of Switzerland announced the formation of the International Anti-Corruption Prosecutorial Taskforce (Taskforce) to strengthen collaboration in the fight against bribery and corruption. This announcement came just over a month after U.S. President Donald Trump issued an executive order “pausing” criminal enforcement of the FCPA (FCPA EO), following which several DOJ investigations and were delayed, dismissed or closed. In this guest article, Alston & Bird partners Albert Stieglitz and Kelly Hagedorn, along with senior associate Sophia Lekakis, discuss how the FCPA EO may open up space for other enforcement authorities, such as the new Taskforce, to step into the void. See “2024 in Review: International Cooperation Continues to Drive ABAC Enforcement” (Dec. 18, 2024).

Rethinking Click-Through Training: Integration Into a Comprehensive Training Program

Given click-through training’s ease of deployment, scalability and trackability, its status as a compliance mainstay is likely to persist. However, to deliver and reinforce long-lasting behavioral change, click-through trainings need to be embedded within a broader compliance training framework that mixes asynchronous online learning with live learning (ideally, the in-person sort) and leadership engagement. This final installment in a three-part series discusses how companies can embed click-through compliance training into a broader program and offers suggestions for choosing the right training vendor. The first article addressed the merits and drawbacks of click-through training. Part two offered suggestions on customization and strategies for measuring effectiveness. See “Compliance 5.0: A Culture-Centered Approach” (Jan. 17, 2024).

How Companies Doing Business in China Should Adjust to the New FCPA Enforcement Landscape

The broad reach of the FCPA has meant historically that companies with commercial ties to China and jurisdictional ties to the U.S. were prime targets for FCPA enforcement. While an executive order has temporarily “paused” FCPA enforcement, foreign companies subject to FCPA jurisdiction – and, in particular, companies with operations in or ties to China – must not assume that the era of aggressive anti-bribery enforcement is over. In this guest article, Pillsbury partners Adam Goldberg and Richard Donoghue discuss how the FCPA seems poised to remain a powerful tool that the U.S. government can wield against foreign businesses to promote U.S. policy interests and how companies doing business in China should react. See this two-part series on the FCPA executive order: “The Future of U.S. Enforcement” (Mar. 12, 2025), and “Staying the Course in the Face of Continued Risk” (Mar. 26, 2025).

NAVEX Study Finds Incident Reporting Steady, But Substantiation Rates Rising

Internal reporting mechanisms enable employees to bring business- and workplace-related issues to the attention of their organizations. Each year, NAVEX, a provider of risk and compliance management software, analyzes the incident reports and inquiries logged by its customers. This article distills key findings from that report and the insights offered during a related webinar featuring Carrie Penman, chief risk and compliance officer at NAVEX; Jane Norberg, a partner at Arnold & Porter and former Chief of the SEC Office of the Whistleblower; and Anders Olson, senior manager of the NAVEX data science team. See “NAVEX Study Finds Record Level of Incident Reports and Substantiated Claims” (Jun. 5, 2024).

Redefining Compliance From a Consumer-Centric Obligation to Product-Embedded Enablement

Compliance, once a function that followed innovation, must now move ahead of it. The paradigm is shifting as organizations transition from responding to regulatory demands to embedding compliance directly within product design, development and delivery. In this guest article, Nikhil Sarnot, a managing director at Accenture Security, discusses how data protection compliance must evolve from an oversight function into a foundational enabler and offers practical steps for shaping the way compliance teams achieve that goal. See our AI Compliance Playbook: “Traditional Risk Controls for Cutting-Edge Algorithms” (Jun. 23, 2021), “Seven Questions to Ask Before Regulators or Reporters Do” (Jul. 21, 2021), and “Adapting the Three Lines Framework for AI Innovations” (Aug. 4, 2021).

Former Federal Prosecutor Joins Ropes & Gray in New York

Sarah Coyne has joined Ropes & Gray as a partner in the firm’s litigation and enforcement practice in New York. She arrives from Weil. For commentary from Coyne, see “What the $850 Million MTS Settlement Signals About FCPA Enforcement, Disclosure and Cooperation” (Apr. 3, 2019).

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Women to Watch: Contributions, Achievements and Observations of Outstanding Female Professionals

To mark International Women’s Day, women editors and reporters at ION Analytics interviewed outstanding women in the industries and jurisdictions we cover. In this part, Law Report Group editors Jill Abitbol, Robin L. Barton and Megan Zwiebel profile notable women in data privacy, cybersecurity, private funds and anti-corruption law, including Anne-Gabrielle Haie, Jessica Lee, Micaela McMurrough, Laura Perkins, Amanda Raad, Madelyn Calabrese, Ranah Esmaili and Genna Garver. Enjoy reading their inspiring remarks here.