Each December, the FCPA bar gathers at conferences offering opportunities to reflect on the previous year and prognosticate on the year to come. In 2025, those conversations looked somewhat different from years past, after a tumultuous 10 months of executive orders, changes in DOJ staff, and new enforcement priorities and guidance. This article, the first in a series looking back at 2025, synthesizes comments made by DOJ leaders at two recent white-collar enforcement conferences about what it means to prosecute “the right way” and why the defense bar might want to watch what it says. Additional articles will examine how anti-corruption legal practices have shifted and morphed for enforcers, defense counsel and in-house experts as a result of the changes wrought in 2025. See “Matthew Galeotti on the LiMu Declination and What to Expect in FCPA Enforcement” (Nov. 19, 2025).
