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.

“Miami rice” — that’s what the Haitians called it: cheap, stateside-subsidized grain whose large-scale importation nearly killed the crop’s domestic cultivation. The plan — as established by the Caribbean Basin Initiative in the early 1980s — was to promote diversification of Haiti’s economy, comparable to the“structural adjustments” demanded globally by the World Bank during the next decade.

Compliance teams operating globally must navigate both international anti-corruption regulations and local laws. The UK Bribery Act and the Foreign Corrupt Practices Act (FCPA) provide bright-line rules. However, real world interactions are often more complex and do not neatly align with rules. In some places, offering a small favor or a gift is a sign of hospitality and respect, not an attempt to create undue influence.

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.

Depending on whom you ask, U.S. President Donald Trump’s Executive Order pausing enforcement of the Foreign Corrupt Practices Act is either the end of anti-corruption as we know it, or the beginning of a needed discussion about how the law is enforced. But lost in the hand-wringing and pish-poshing is perhaps the most important question for businesses: How will America’s competitors react?