FCPA enforcement after the guidance issued in June 2025 shows two parallel, but competing dynamics. On one track, the DOJ has curtailed enforcement, including early termination of DPAs, NPAs, monitorships and active investigations. On the other, it has pursued enforcement against individuals and a small number of companies where it can tie the conduct, however attenuated, to current policy priorities such as national security, cartels, critical infrastructure or major U.S. financial‑system touchpoints. The net result is an active but less predictable FCPA enforcement landscape in which the rationale for outcomes is not always immediately evident. In this guest article, A&O Shearman partner Paula Howell Anderson, with associates Justin Meshulam and Sanjna Ullal, analyze the most salient FCPA developments of 2025 and offer practical insights on identifying, assessing and mitigating emerging compliance risks. See this three-part series “2025 in Review”: White-Collar Enforcement the “Right Way” Remains a Priority (Dec. 17, 2025), DOJ Perspectives on How the Blanche Memo Restarted FCPA Enforcement (Jan. 14, 2026), and “Impact on In-House Teams and Their Defense Counsel” (Jan. 28, 2026).