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    Jan. 28, 2026

2025 in Review: Impact on In-House Teams and Their Defense Counsel

While DOJ enforcers have made it clear that they will continue to prosecute white-collar crime in general and FCPA violations in particular, the reality on the ground for in-house professionals and those that advise them is a little more nuanced. With staffing reductions and shuffles at the DOJ, the apparent dissolution of the SEC’s FCPA Unit and enforcement ramping up in other arenas, many companies are making corresponding adjustments in their compliance programs. This third and final article in a series analyzing how anti-corruption enforcement changed in 2025 examines how Trump administration policies have impacted companies and the practices of law firm attorneys who advise them, drawing from interviews with defense counsel and statements made by DOJ enforcers at the American Conference Institute’s 42nd Annual Conference on FCPA. See our two-part series on emerging global compliance standards: “DOJ, OECD and World Bank Guidance” (Oct. 22, 2025), and “AFA, SFO and Eight Common Compliance Elements” (Nov. 5, 2025).

Understanding Human Behavior to Design Better Crisis Management Protocols

A company’s operations unfold differently in everyday situations than in a crisis. Resilient crisis management protocols (CMPs) take this reality into account by establishing a set of expectations and touchpoints that shape how people communicate, make decisions and escalate issues as conditions change. In this guest article, Michelle DiMartino and Nitish Upadhyaya of Ropes & Gray’s R&G Insights Lab highlight three issues that often arise in the midst of crisis, analyze the human and behavioral mechanisms that give rise to these issues and offer suggestions for how to assess and design CMPs in light of those patterns. See “Compliance 5.0: A Culture-Centered Approach” (Jan. 17, 2024).

Staying Compliant After State AI Laws EO Introduces Regulatory Uncertainty

In the absence of congressional action to implement a national artificial intelligence (AI) bill, President Donald Trump’s December 11, 2025, executive order (EO) announcing U.S. AI policy was an eagerly anticipated development for companies seeking guidance from the federal government. The EO requires federal agencies to take multiple actions to promote U.S. AI dominance and encourages the creation of a DOJ litigation task force to challenge state laws regulating AI. This article analyzes the EO’s key provisions, which state AI laws the administration may target and what companies can do to address the complex and uncertain regulatory landscape. See “Implications of the Trump AI Executive Order” (Apr. 9, 2025).

In‑House Insights on Optimizing Compliance Culture

A strong culture of compliance can be labor intensive to build but a lifesaver when the outside regulatory environment becomes precarious and unpredictable. In a panel discussion at the New York City Bar’s Compliance Conference 2025, in-house experts offered insights on the elements of a strong compliance culture, how companies can work to optimize their culture and methods for measuring the strength of that culture through turbulent times. This article synthesizes key takeaways from the presentation. See “Survey Finds Increased Value in Having a Culture of Compliance” (Feb. 26, 2025).

Managing Off‑Channel Communications in Internal Investigations

In virtually any organization, employees sometimes send work-related messages through channels other than those that are officially condoned but off-channel communications can make collecting evidence in an internal investigation difficult, to say the least. At a panel during SCCE’s 24th Annual Compliance & Ethics Institute, experts shared advice on constraining and tracking off-channel communications. This article distills their insights. See “How Internal Investigations Can Let the Compliance Team Shine” (Jan. 29, 2025).

Former DOJ Fraud Section Chief and HPE CECO Joins Jenner & Block

Jenner & Block has welcomed former DOJ Fraud Section Chief Glenn Leon as a partner in its investigations, compliance and defense practice in Washington, D.C. For commentary from Leon, see “Executive Order Presses Pause on FCPA Enforcement” (Feb. 12, 2025).

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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.