What Does the FCPA EO Mean for European Enforcement?

There is no doubt that the FCPA has been the most impactful piece of global legislation in the fight against corruption, and its enforcement by the DOJ has been the “gold standard” for decades. So, on the face of it, the recent U.S. executive order pausing FCPA enforcement (FCPA EO) issued by President Donald Trump on February 10, 2025, has the feel of an existential change when it comes to the crackdown on international corruption. However, recent global trends – across Europe in particular – point to a shift in the balance. In this guest article, Laim Naidoo, a partner at Hogan Lovells looks at how developments in the U.S. could impact anti-corruption efforts in the U.K., France, Switzerland, Germany, Italy, Spain and beyond. For more on the FCPA EO, see our two-part series: “The Future of U.S. Enforcement” (Mar. 12, 2025), and “Staying the Course in the Face of Continued Risk” (Mar. 26, 2025).

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