FCPA Enforcement Trends in 2025: What Compliance Leaders Need to Know

Corruption risk isn’t just a legal concern. It’s a business reality for organizations with global reach. In 2024, U.S. authorities brought 38 FCPA enforcement actions, resulting in over $1.5 billion in corporate penalties, the highest total in five years. These numbers underscore a simple truth: even as enforcement priorities shift, the Foreign Corrupt Practices Act (FCPA) remains a powerful force shaping compliance programs and executive decision-making.

If you’re a compliance officer, risk manager, or executive, you know the stakes are high, and the rules are always evolving. This blog will break down the latest FCPA enforcement trends, explain what’s driving recent changes, and highlight what your organization should be doing now to stay ahead. 

TL;DR

• DOJ prioritizes serious misconduct tied to U.S. national security and economic interests (e.g., defense, energy, critical infrastructure).
• Low-risk or routine violations (like facilitation payments) are deprioritized—but not off the radar.
• Individual accountability is central—executives and decision-makers are a primary focus.
• All new FCPA cases require high-level DOJ approval, tightening oversight and political alignment.
• Foreign companies face more scrutiny if their actions harm U.S. interests or distort fair competition.
• Proactive compliance is non-negotiable—programs must document good-faith efforts, monitor risks continuously, and respond fast to red flags.

What is the FCPA?

The Foreign Corrupt Practices Act (FCPA) is a landmark U.S. federal law enacted in 1977 to combat bribery and corruption in international business. The FCPA makes it illegal for U.S. companies, their employees, and certain foreign entities to bribe foreign officials in order to obtain or retain business. It consists of two main provisions:

• Anti-Bribery Provisions: Prohibit offering, promising, or giving anything of value to foreign officials to influence their actions or secure an improper advantage.
• Books and Records/Internal Controls Provisions: Require publicly traded companies to maintain accurate records and implement robust internal accounting controls to prevent and detect improper payments.

The FCPA applies to:

• U.S. companies and citizens
• Foreign companies listed on U.S. stock exchanges
• Certain foreign persons or entities acting within U.S. territory

Over the decades, the FCPA has become a central tool for U.S. authorities to promote ethical business practices globally and level the playing field for companies operating abroad. Recent updates and enforcement guidelines continue to shape how organizations approach anti-corruption compliance, particularly as enforcement priorities evolve to address national security and economic interests. Now that we’ve covered the basics of the FCPA let’s look at the key agencies responsible for enforcing these anti-corruption laws.

Read: The Ultimate Guide To Implementing Internal Controls

Regulatory Bodies Overseeing FCPA

The enforcement of the Foreign Corrupt Practices Act (FCPA) in the United States is primarily the responsibility of two federal agencies: the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC).

Department of Justice (DOJ):

• The DOJ is responsible for criminal enforcement of the FCPA.
• It investigates and prosecutes companies and individuals, both U.S. and certain foreign entities, who violate the anti-bribery provisions of the law.
• The DOJ can bring criminal charges that may result in significant fines and, for individuals, imprisonment.
• In 2024, the DOJ led a notable uptick in enforcement actions, continuing its focus on both corporate and individual accountability.

Securities and Exchange Commission (SEC):

• The SEC handles civil enforcement of the FCPA, focusing on companies with securities registered in the U.S. or those required to file reports with the SEC.
• Its jurisdiction covers violations of the FCPA’s accounting provisions, such as failures in maintaining accurate books and records or insufficient internal controls.
• The SEC may impose civil penalties, disgorgement of profits, and other remedies.

The dual-agency approach ensures that both criminal and civil violations of the FCPA are addressed, reinforcing the law’s reach and impact on global business conduct.

With a clear understanding of the main regulatory bodies, it’s helpful to examine how their enforcement strategies have evolved in recent years.

2024–2025 FCPA Enforcement: Key Developments

In 2024, enforcement of the Foreign Corrupt Practices Act (FCPA) remained strong, with the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) bringing a total of 38 enforcement actions. 

These included 14 corporate cases and 24 individual prosecutions, reflecting a continued focus on holding both companies and executives accountable. The total penalties collected exceeded $1.5 billion, the highest in five years, underscoring the seriousness with which regulators approach anti-corruption violations.

However, in February 2025, a significant change occurred. An executive order was issued that paused all new FCPA investigations and enforcement actions for 180 days. During this period, the DOJ and SEC were instructed to review their enforcement policies and prioritize cases involving serious criminal conduct, such as cartel activity and transnational crime, over routine business violations. 

This pause also required the agencies to reassess ongoing investigations to ensure they align with the new priorities.

What this means for your organization:

• Enforcement is becoming more targeted but remains rigorous.
• Compliance programs must be prepared for continued scrutiny.
• Proactive risk management and documentation are critical to avoid penalties.
• Staying informed about regulatory changes is essential for timely adjustments.

As enforcement trends evolve, many organizations are seeking technology solutions that help them keep pace with changing regulatory expectations. Platforms like VComply are designed to support compliance teams in tracking updates and maintaining readiness for new enforcement priorities.

These recent developments set the stage for the significant changes to FCPA rules and enforcement priorities introduced in 2025.

FCPA Rules and Enforcement Priorities in 2025

In June 2025, the U.S. Department of Justice (DOJ) released new guidelines for enforcing the Foreign Corrupt Practices Act (FCPA), officially ending the 180-day suspension that began in February 2025. These guidelines represent a major shift in how the FCPA will be applied and enforced going forward.

Key Changes in 2025 FCPA Rules

1. Focus on U.S. National Interests

• FCPA enforcement is now explicitly tied to protecting American economic and strategic interests.
• The DOJ will prioritize cases where misconduct directly harms U.S. companies, national security, or critical industries (such as defense, energy, and infrastructure).

2. Targeting Serious Criminal Conduct

Investigations and prosecutions will focus on high-stakes cases, especially those involving:

• Transnational criminal organizations (TCOs)
• Money laundering through shell companies
• Bribery of foreign officials linked to criminal groups
• Conduct causing substantial economic harm to U.S. entities

3. Reduced Burden on U.S. Companies

• Routine or low-severity violations, especially those that do not directly undermine U.S. interests, are less likely to be pursued.
• Facilitation payments or practices tolerated under local law are no longer a priority for enforcement.

4. Increased Political Oversight

• All new FCPA investigations and prosecutions must be approved by the Assistant Attorney General for the Criminal Division, ensuring greater oversight and alignment with national policy.

5. Individual Accountability

• The DOJ will continue to prioritize prosecuting individuals over corporations, particularly in cases involving clear fraudulent intent or substantial amounts.

6. Coordination with Foreign Authorities

• The DOJ will consider whether foreign authorities are capable and willing to prosecute alleged misconduct. If American interests are not directly implicated, the U.S. may defer to foreign counterparts, though parallel proceedings remain a risk.

The 2025 FCPA guidelines reflect a more strategic enforcement approach. Companies should review their compliance frameworks to ensure they are aligned with these new priorities and prepared for increased scrutiny in high-risk scenarios.

With these new rules in place, both U.S. and foreign companies must adapt their compliance approaches to address shifting risks and expectations.

How the 2025 FCPA Rules Impact U.S. and Foreign Companies

The new FCPA enforcement guidelines, published by the Department of Justice (DOJ) on June 9, 2025, have reshaped how both U.S. and foreign companies must approach anti-corruption compliance. The DOJ’s updated strategy now closely aligns FCPA enforcement with the protection of U.S. economic and strategic interests, reflecting the administration’s “America First” policy.

What’s Changed for Companies in 2025

• Targeted Enforcement: The DOJ will now focus its efforts on high-stakes cases, especially those that threaten U.S. national security critical industries (like defense, energy, and infrastructure), or cause significant economic harm to American companies.
• Reduced Focus on Routine Violations: Minor or locally tolerated practices, such as facilitation payments, are no longer a priority for enforcement. The DOJ aims to curb what it calls “abuses” in FCPA enforcement that previously burdened U.S. companies operating abroad.
• Heightened Risk for Foreign Companies: Foreign companies whose business activities harm U.S. interests, distort competition, or involve transnational criminal organizations (TCOs) face a greater risk of prosecution by U.S. authorities.
• Approval and Oversight: All new FCPA investigations and prosecutions must now be approved by the Assistant Attorney General for the Criminal Division, ensuring greater political oversight and consistency with national priorities.
• Review of Ongoing Cases: Existing FCPA investigations are being reviewed under the new guidelines. Many low-severity cases have already been closed or dismissed, while those involving serious criminal conduct remain active.
• Coordination with Foreign Authorities: The DOJ will consider whether foreign regulators are willing and able to prosecute alleged misconduct. If U.S. interests are not directly implicated, the U.S. may defer to foreign authorities, though companies should be aware of the risk of parallel proceedings in multiple jurisdictions.

Given these challenges, compliance and risk leaders need actionable strategies to ensure their organizations remain protected and prepared.

Practical Takeaways for Compliance and Risk Leaders

The DOJ’s new FCPA guidelines, effective June 2025, require compliance and risk leaders to rethink their anti-corruption strategies. While enforcement is now more targeted, focusing on cases that impact U.S. economic and national security interests, regulators continue to expect robust compliance programs, especially in high-risk industries and transactions.

Key actions compliance teams should prioritize:

• Review and Update Compliance Programs: Ensure your anti-bribery and anti-corruption policies are aligned with the DOJ’s new priorities. Focus on risks related to critical sectors (defense, energy, infrastructure) and transactions that could impact U.S. interests.

• Enhance Due Diligence: Increase scrutiny of third parties, joint ventures, and high-risk markets, especially where there is potential exposure to cartels, transnational criminal organizations, or government officials.
• Document Good-Faith Efforts: Maintain detailed records of compliance training, risk assessments, and internal investigations. The DOJ’s new approach is more favorable to companies that can demonstrate proactive, good-faith compliance efforts.
• Monitor Regulatory Developments: Stay informed about further changes in FCPA enforcement and related statutes. The DOJ has signaled that additional adjustments in priorities may occur, and the SEC or other agencies may continue their own anti-corruption work.
• Prepare for Parallel Proceedings: Even as the DOJ narrows its focus, foreign regulators and state authorities may increase their own enforcement. Companies should be ready for investigations in multiple jurisdictions.
• Prioritize Individual Accountability: The DOJ’s guidelines emphasize prosecuting individuals for serious misconduct. Ensure your compliance program includes clear reporting channels and protections for whistleblowers.

The new FCPA approach does not eliminate enforcement risk. It shifts the focus. Compliance teams must be agile, proactive, and ready to respond to both U.S. and international scrutiny. A strong compliance program remains the best defense against enforcement actions and reputational harm.

To put these strategies into practice, many organizations are turning to advanced compliance platforms that can streamline their efforts and boost effectiveness.

How VComply’s Platforms Power FCPA Compliance in 2025

The DOJ’s 2025 FCPA guidance places greater emphasis on real-time risk management, individual accountability, and sector-specific exposure. To keep pace, organizations are turning to systems that can provide structure, visibility, and adaptability across their compliance operations.

VComply’s modular, cloud-based suite offers that foundation. Its core platforms, ComplianceOps, RiskOps, PolicyOps, and CaseOps, are designed to work together to support anti-bribery and anti-corruption efforts across global operations.

• ComplianceOps helps teams organize their processes, automate recurring tasks, and control activities, and maintain audit-ready documentation. Alerts and notifications help prevent missed responsibilities or deadlines.
• RiskOps supports continuous monitoring by mapping and tracking bribery and corruption risks across business units, regions, and third parties. It enables quick escalation of high-risk issues in sensitive sectors.
• PolicyOps simplifies how organizations create, update, and communicate policies, while enabling employee training and attestation aligned with current DOJ and SEC expectations.

The platform also offers capabilities for secure case management, customizable dashboards for leadership visibility, and flexible scaling across jurisdictions, key features for organizations responding to an evolving enforcement landscape.

As regulatory expectations shift, tools like VComply enable compliance teams to stay current, reduce manual work, and maintain a clear, well-documented compliance posture.

Wrapping Up

FCPA enforcement has shifted significantly in 2025, with U.S. regulators emphasizing targeted action against serious criminal conduct and risks to national interests. For organizations, this means compliance programs must be more focused, data-driven, and adaptable than ever before. Staying ahead requires not only understanding these new priorities but also having the right systems in place to manage evolving risks, maintain robust documentation, and respond quickly to regulatory changes.

VComply stands out as a strategic partner for organizations navigating these challenges. Its integrated platforms enable centralized compliance management, real-time risk monitoring, and seamless policy updates. With VComply, you gain a streamlined, audit-ready approach that aligns with the DOJ’s latest expectations and supports a proactive culture of integrity and accountability.

Ready to strengthen your FCPA compliance for 2025 and beyond?

Request a demo today to discover how our platform can help you build a resilient, future-ready compliance program that keeps your organization protected and prepared for whatever comes next.

FAQs

1. How do the new FCPA guidelines affect U.S. companies operating abroad?

The guidelines aim to limit undue burdens on American companies operating overseas. Routine or minor violations are less likely to be prosecuted, but companies must still maintain robust compliance programs to prevent and detect serious misconduct.

2. What should companies do to comply with the updated FCPA guidelines?

Companies should review and strengthen their anti-bribery compliance programs, focus on high-risk sectors and transactions, ensure thorough documentation, and be prepared to demonstrate good-faith compliance efforts if investigated.

3. Are foreign companies subject to FCPA enforcement?

Yes, foreign companies can be prosecuted under the FCPA if their conduct has a sufficient connection to the United States, such as using U.S. banking channels or competing unfairly with U.S. companies through bribery.

4. What is the role of internal controls and recordkeeping under the FCPA?

Maintaining accurate books, records, and internal controls remains a core requirement under the FCPA, helping companies detect and prevent bribery and other forms of corruption.

5. How can companies stay updated on FCPA enforcement trends?

Companies should monitor DOJ and SEC announcements, review updated compliance guidance regularly, and consult with legal counsel or compliance experts to ensure ongoing alignment with enforcement priorities.