Quinn Emanuel Partners Stephen Frank, Sarah Heaton Concannon, Sam Nitze, Kurt Wolfe and Associate Abbey Foote unpack President Trump's recent Executive Order on FCPA enforcement in their latest Reuters article.
The analysis reveals crucial insights for global businesses:
- Analysis of the rate of FCPA enforcement during the prior Trump, Obama and Biden administrations
- Assessment of SEC's civil enforcement authority under the statute's books and records provisions
- Implications of the 180-day enforcement pause and the applicable statute of limitations
- Strategic considerations for entities under active investigation during the review period
- The research concludes that while near-term enforcement may shift significantly, the FCPA's fundamental legal framework remains intact.
Their conclusion? Reports of the FCPA's death may be exaggerated, particularly over the long term.
Read the full analysis here.