President Trump’s recent pause on the enforcement of the Foreign Corrupt Practices Act (FCPA), which prohibits companies from bribing foreign government officials, now prevents federal prosecutors from launching new investigations or taking enforcement actions for the next 180 days.

While key uncertainties remain—particularly regarding the status of ongoing investigations and the impact on the SEC—Corporate Investigations & White Collar Defense partner Richard Donoghue told the New York Times that, if the Justice Department’s FCPA Section steps back, local U.S. attorneys may initiate FCPA cases following the pause.

He also suggested that the focus could shift toward prosecuting individuals who engaged in bribery, rather than targeting companies.

“Going forward, this creates more opportunities for businesses to argue to prosecutors that they should not be held liable for the misconduct of their employees,” Donoghue said.

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