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“Pausing” FCPA Enforcement – Much Ado About Nothing New? [Forbes]

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livelihood in that arena – that FCPA enforcement would disappear. An evaluation of Trump's past rhetoric and actions and the FCPA's benefits for American business suggests that foreign corruption enforcement is not going anywhere soon. Trump's direction to put prosecution of current FCPA actions on hold and not initiate any new actions while the Attorney General reviews and revises FCPA policies and guidelines supposedly is rooted in “ ,” and .” The irony is that FCPA enforcement actually has advanced American businesses' competitiveness in the global economy. As the and others correctly predicted eight years ago, Trump's public statements disapproving of the FCPA—he has called it a and has said FCPA prosecutions are “absolutely crazy”—have meant little for FCPA enforcement. Despite Trump's supposed effort to for business reasons during his first term, DOJ remained in initiating new FCPA enforcement matters. Another indication that Trump's statements yet again are unlikely to have tee
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