On February 10, 2025, President Donald Trump signed an Executive Order (“Order”) directing a 6-month moratorium on the enforcement of the Foreign Corrupt Practices Act (FCPA), while the Attorney General revises Department of Justice (DOJ) policies and guidelines governing FCPA enforcement. The Order instructs that these changes be made in the interest of promoting US companies’ ability to compete in foreign markets. While the Order introduces uncertainty for the future of FCPA enforcement, companies are advised to stay the course on compliance and exercise caution when considering any shifts in compliance practices and resourcing in the near term.

On November 1, 2015, several important amendments to the U.S. Sentencing Guidelines became effective. The amendments include changes to the guidelines governing fraud and economic crime that will have a significant impact on the prosecution of individuals for a wide range of conduct. We summarize several of the amendments that could have a significant impact on sentencing and settlement negotiations in FCPA cases.