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Executive Order

#14209 – Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security (Feb. 14, 2025)

Highlights

180-day DOJ pause; SEC still active including SEC enforcement.

Key Compliance/Risk Cue

The FCPA remains a valid federal law, and bribery of foreign officials is still illegal. The executive order temporarily halts DOJ enforcement but does not repeal the law. The Securities and Exchange Commission (SEC), which enforces the FCPA's civil provisions, has not been directed to pause its enforcement activities. Therefore, companies may still face civil enforcement actions from the SEC .

Litigation Snapshot

None.

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