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.

A Legal Tightrope for Government Contractors In brief President Trump’s Executive Order 14173 calls for the elimination of what it characterizes as “illegal” DEI programs in the federal government. In addition, by making express references to the False Claims Act, the order provides another avenue for qui tam relators to…

A recent memorandum from Attorney General Pam Bondi signals a potential shift in the Department of Justice’s FCPA enforcement priorities. According to the memorandum, FCPA enforcement should prioritize foreign bribery linked to Cartels and Transnational Criminal Organizations (TCOs), potentially altering the landscape of white-collar corporate enforcement. While traditional FCPA cases will likely continue, the new directive grants local US Attorneys’ Offices greater latitude in conducting FCPA investigations touching on Cartels and TCOs.

Having not secured a deferred prosecution agreement in respect of U.K. Bribery Act offences since 2021 and having been rocked by a series of shortcomings regarding its investigation and prosecution of cases, the SFO has arguably been at its lowest ebb.

View the recorded sessions from our 2023 Virtual Global Trade Conference where international trade compliance lawyers from around the world reviewed major developments impacting international trade.

Baker McKenzie’s Government Procurement Update resource center gives you the latest guidance, trends and enforcement actions related to government procurement (both US government contracting and international financing institutions), including suspension and debarment, bid protests, and False Claims Act defense. Calling upon our deep bench of more than 4,000 lawyers and legal professionals worldwide, we will occasionally feature guest practitioners to write about related topics in the criminal, civil, and administrative context. Readers can expect to find practical guidance and tips for compliance with public procurement policies as well as best practices for managing government inquiries and litigation.

In a sign that Congress continues to pursue bipartisan efforts to combat the use of forced labor in supply chains, Senators Josh Hawley and Kirsten Gillibrand have reintroduced the Slave-Free Business Certification Act of 2022. The Act would impose significant new compliance and disclosure requirements for many companies, requiring businesses with annual, worldwide gross receipts exceeding USD 500 million to conduct annual audits of their supply chains to detect any use of forced labor, report findings to the US Government, and face potentially significant fines and penalties for violations.

On 24 February 2022, various US government agencies published their respective reports on supply chain policies for six key industrial bases pursuant to Executive Order 14017, “America’s Supply Chains”. These Reports identify key weaknesses in some of the nation’s most crucial supply chains and offer multi-year strategies to help address those weaknesses. The White House issued a statement and capstone report following the publication of the Reports.

Brian Whisler and Aleesha Fowler have co-authored a chapter in The Complete Compliance and Ethics Manual 2022.

Welcome to The Employer Rapport, Baker McKenzie’s Labor and Employment video chat series for US multinational employers. In each on-demand episode, our lawyers provide insights and quick, practical tips on today’s most pressing issues and legal developments impacting employers both at the domestic and global levels. This week we discuss What’s the Fate of the Federal Contractor Vaccine Mandate After SCOTUS’s Stay of the OSHA ETS?