In a previous piece in conversation with Severin Wirz, ethics and compliance attorney (and former TRACE staffer) about his book Bribery Beyond Borders: The Story of the Foreign Corrupt Practices Act, I covered his telling of the pre-history of the FCPA. In this second of a two-part series, I explore how Wirz thinks the anti-corruption movement should now move forward, particularly following first the FCPA pause, and now the changes in FCPA enforcement.

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