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June 18, 2025
Cadwalader partner Martin Weinstein was quoted in a recent Global Investigations Review article analyzing the U.S. Department of Justice’s (DOJ) newly released guidelines on Foreign Corrupt Practices Act (FCPA) enforcement.
In the piece, Martin addressed the white-collar bar’s concerns following a four-month pause on FCPA enforcement under the Trump administration. “The rumors of the death of the FCPA have been exaggerated,” he said. “The pause is over, the FCPA is back and alive, and those companies that have held fast to their compliance programmes are feeling pretty good about their decisions.”
He also flagged potential challenges ahead, particularly for foreign companies with U.S. ties. “Is it going to become open season internationally on U.S. companies? Are we going to have, effectively, an FCPA-style trade war where we go after foreign companies, and they go after U.S. companies?” he asked.
Martin concluded by questioning whether the DOJ will have sufficient resources to carry out its new enforcement priorities, following calls for personnel cuts in key offices.
Read the full article here (subscription required).
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