Part One: A case-by-case analysis of FCPA investigation closures
By 
Jaclyn Jaeger2025-11-18T21:06:00
Foreign corruption enforcement relating to national security matters has been a common theme under the Trump administration. A second common theme continues to be the discrete way in which the U.S. Department of Justice (DOJ) has ended several Foreign Corrupt Practices Act (FCPA) investigations.
The clandestine nature of these operations leaves much to be desired in the way of illustrative lessons for the legal and compliance community, which evolves, matures, and thrives only when true transparency is met with clear accountability.
This first article in a two-part series provides a collective case-by-case analysis of which known FCPA investigations have been closed by the DOJ, as disclosed by the investigated companies.
Related articles
-
PremiumPart Two: FCPA cases closed by DOJ, SEC since January
Since the start of the Trump Administration, the Department of Justice has been winding down a number of Foreign Corrupt Practices Act investigations with little public attention. This second article further explores how and why these FCPA matters have been closed.
-
News BriefDOJ secures $118 million penalty in FCPA violation case tied to Guatemalan telecom firm
The parent company of a telecom subsidiary in Guatemala agreed to pay $118.2 million to settle allegations of improper payments made to government officials, but the U.S. Department of Justice chose not to impose a compliance monitor to administer the firm’s compliance with the Foriegn Corrupt Practices Act (FCPA).
-
PremiumQ&A with former FCPA Unit chief Charles Duross on the DOJ’s monitorship policy
Compliance Week recently interviewed Charles Duross, former Chief of the DOJ’s Fraud Section’s FCPA Unit, to talk about the Department of Justice’s recently revised monitorship policy.
More from Regulatory Enforcement
-
News BriefSEC dismisses SolarWinds case tied to 2020 cyberattack
The dismissal of charges against SolarWinds for alleged cybersecurity lapses related to a 2020 Russian cyberattack in 2020 are the latest in a continuing pattern of leniency for corporations by the Trump administration.
-
News BriefCFPB shutdown appears imminent, enforcement transferred to DOJ
The Consumer Financial Protection Bureau is reportedly transferring its enforcement caseload to the DOJ, one of multiple indicators telegraphing its eminent shutdown.
-
ArticleRussian web company that hosted LockBit ransomware sanctioned
Two Russian web-hosting services that provide cover for ransomware operators, including Lockbit, have been sanctioned by the U.S. Treasury’s OFAC and international partners.