FCPA Enforcement in 2025: What Corporations Need to Know
DOJ signals renewed focus on individual accountability
Sterling & Ghold's team of experienced practitioners brings decades of specialized expertise to every matter, combining deep industry knowledge with practical commercial judgment. Our lawyers work seamlessly across offices and practice groups to deliver integrated advice that addresses the full scope of our clients' objectives.
The Department of Justice has signaled a renewed commitment to Foreign Corrupt Practices Act enforcement, with the FCPA unit adding resources, accelerating the pace of investigations, and taking an increasingly aggressive posture on individual accountability. Companies with international operations face heightened risk and should review their compliance programs accordingly.
Sterling & Ghold's team of experienced practitioners brings decades of specialized expertise to every matter, combining deep industry knowledge with practical commercial judgment. Our lawyers work seamlessly across offices and practice groups to deliver integrated advice that addresses the full scope of our clients' objectives.
Among the trends we are watching: increased use of data analytics to identify potential violations; growing focus on third-party intermediaries in emerging markets; and the DOJ's continued reliance on the FCPA corporate compliance program guidance to distinguish between companies that self-disclosed promptly and those that did not.
