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).
