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.
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