Now that the Trump administration has passed its first 100 days, some additional insights are available with respect to how the administration plans to enforce anti-corruption laws, including the Foreign Corrupt Practices Act (“FCPA” or the “Act”). Moreover, all signs from the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”), including recent statements by recently appointed Attorney General Jeff Sessions and SEC Chair Jay Clayton, indicate that both will continue to investigate and prosecute violations of the FCPA in a manner similar to that of their predecessors. Accordingly, companies subject to the Act should continue to prioritize robust compliance procedures and a proactive compliance mindset.
