US Justice Department Resumes Narrow Foreign Bribery Enforcement After Trump Pause

The U.S. Justice Department has resumed enforcement of the Foreign Corrupt Practices Act (FCPA) with a narrowed focus following a review ordered by President Donald Trump, who had paused investigations earlier this year citing concerns that enforcement disadvantaged American firms. The department's approach will prioritize cases that protect U.S. strategic interests, including those involving key infrastructure, cartel operations, and transnational criminal organizations. As part of this shift, the team of prosecutors dedicated to foreign bribery enforcement has been reduced from 32 to about 15, with many reassigned to other units such as healthcare and marketplace fraud. Attorney General Pam Bondi has directed a focus on cases related to drug cartels, marking a change from traditional enforcement priorities. New guidance on handling FCPA cases is expected soon, emphasizing prosecutorial discretion to decline cases when companies self-report, cooperate, and remedy issues. This scaled-back enforcement reflects a broader Trump administration effort to reduce burdens on U.S. companies while maintaining critical anti-corruption efforts.