Consequences of Trump Administration Pausing FCPA Enforcement

In early February 2025, the Trump Administration announced Executive Order “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security”, which appears to be intended to substantially scale back FCPA enforcement by the Department of Justice (DOJ) in furtherance of the new Administration’s “America First” agenda.

AmCham members benefitted from a webinar that explained the expected changes in DOJ’s enforcement priorities, and how they are being applied. Critical questions were answered as to what these changes mean for Danish companies, including:

• Will FCPA enforcement cease altogether or simply change focus?
• What about FCPA enforcement by other U.S. agencies like the SEC and CFTC?
• How will EU react to the possible change of level playing field?
• What do these changes and prospects mean for anti-bribery and anti-corruption compliance programs at multi-national corporations in Denmark and abroad?

Many thanks to our knowledgeable presenters for sharing their expertise: David W. Simon, Partner, Foley & Lardner and Hans Jakob Folker, Partner, Kromann Reumert.