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FCPA Enforcement Back on at DOJ — With a New Look

June 18, 2025

Cadwalader partners Martin Weinstein, Laura Perkins, and Gina Castellano were quoted in a recent Corporate Compliance Insights article analyzing the Department of Justice’s (“DOJ”) renewed enforcement of the Foreign Corrupt Practices Act (“FCPA”) under the Trump administration.

In a written Q&A, Martin, Laura, and Gina emphasized that despite a likely reduction in the number of FCPA cases brought, companies should not mistake this for a complete lack of enforcement.

“The biggest mistake compliance officers could make during this transition is assuming that enforcement is easing in light of the DOJ’s updated priorities and taking their foot off the gas in ensuring their compliance programs are operating effectively,” they said. “The revised focus suggests a more selective but no less aggressive enforcement posture.”

The article also highlights new expectations from DOJ leadership, including expedited investigations, a renewed emphasis on individual misconduct, and stricter gatekeeping on case approvals. Attorneys caution that cases moving forward will likely be higher-stakes and more closely tied to perceived threats to U.S. interests.

Read the full article here (subscription required).

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