When enforcement of the Foreign Corrupt Practices Act (FCPA) was paused in February 2025, ethics and compliance attorney Severin Wirz, previously with TRACE and now at Applied Materials, was finalizing a 10-year project on the law’s history. His resulting November 2025 book, Bribery Beyond Borders: The Story of the Foreign Corrupt Practices Act, truly meets this current moment. In this first of a two-part series from our recent conversation, I examine Wirz’s recounting of the