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).