In July, federal prosecutors secured a significant appellate victory affirming their power to prosecute foreign commercial bribery worldwide. Yet when defendants Hernán Lopez and Full Play Group petitioned for Supreme Court review, the DOJ reversed course, abandoning both the case and the precedent it had just won.

With the halt to the FCPA earlier this year, a lot of compliance teams reached out with questions on what compliance topics remain relevant and top-of-mind with shifting policies.    The shift in enforcement announced by the DOJ in June and the latest declination for FCPA violations announced in August conveyed that there are tried and true compliance topics that should continue to be enforced each and every year, throughout the year. And these should always be top-of-mind.

Earlier this month, the U.S. Department of Justice agreed not to prosecute Liberty Mutual Insurance Company despite evidence that its subsidiary paid nearly $1.5 million in bribes to officers of six state-owned banks in India. As part of the declination agreement, Liberty Mutual enhanced its compliance program, and agreed to disgorge profits.

Since the February 2025 Executive Order pausing enforcement of the Foreign Corrupt Practices Act (FCPA), businesses, lawyers and the anti-corruption community awaited the outcome of the planned 180-day review. On June 9, we received some idea about what lies ahead, as Deputy Attorney General Todd Blanche released the memorandum Guidelines for Investigations and Enforcement of the Foreign Corrupt Practice Act.

In early February, the US Department of Justice announced it was temporarily pausing Foreign Corrupt Practices Act (FCPA) enforcement and adjusting future FCPA enforcement to prioritize Cartels and Transnational Criminal Organizations.

It is true to that compliance enforcement guidance, including an update to the Evaluation of Corporate Compliance Programs from the DOJ in..