Past Event

Shifting Standards: Bribery and Anti-Corruption Enforcement in a New Era

Wed. October 22, 2025 08:30 am - 10:30 am !Bank of Ireland NYC Hub New York, NY 10017

This program will provide an overview of the FCPA and its global influence, as well as a comparison with European equivalents such as the UK Bribery Act or France's comprehensive anti-corruption legislation. This comes in the wake of the Trump administration’s 2025 Executive Order pausing FCPA enforcement, similar DOJ memoranda, and the most recent DOJ Guidelines published on June 9, 2025.

The panel will cover the following topics:

Introduction
• Brief overview of the FCPA and its global influence & European equivalents such as the UK Bribery Act and Sapin II (France)
• Context: Trump administration’s 2025 Executive Order pausing FCPA enforcement for 180 days, similar DOJ memoranda, and the most recent DOJ Guidelines (June 9, 2025)

U.S. Enforcement Landscape Post-2025
• Overview of the 2/10/25 Executive Order:
> Paused new FCPA investigations for 180 days
> Mandated DOJ to revise enforcement guidelines
> Key Motivations: Promote U.S. economic competitiveness; Reduce perceived overreach in enforcement; Reallocate prosecutorial resources
• Overview of the 6/9/25 DOJ FCPA Enforcement Guidelines:
> Goal to Refocus FCPA enforcement to protect U.S. economic and national security interests
> Sets out new enforcement priorities: combatting cartels & TCOs; prioritize cases harming identifiable U.S. companies or individuals; serious misconduct only
> Implementation of this guidance

European Enforcement Trends and Reactions
• Current European Anti-Bribery Frameworks:
> UK Bribery Act, Sapin II (France), EU Whistleblower Directive
•  Reaction to U.S. policy shift
> Concerns about weakening global anti-corruption norms
> Potential for EU to take a leadership role
> Formation of the International Anti-Corruption Prosecutorial Taskforce (IATP)
•  Enforcement trends:
> Increased cross-border cooperation
> More aggressive enforcement by national authorities

Implications for Companies Operating Internationally
• Impact on multinational corporations:
> Navigating diverging U.S. and EU enforcement priorities
> Despite U.S. enforcement pause, European regulators are increasing scrutiny
> Companies must maintain robust anti-corruption programs
> Greater likelihood of European-led enforcement in absence of U.S. action
• Best Practices:
> Maintain robust internal controls
> Monitor evolving guidance from U.S. DOJ, SEC, and the new International Anti-Corruption Prosecutorial Taskforce
> Strengthen third-party due diligence


SPEAKERS:
• Marianne Bloos, Of Counsel, HOUTHOFF
• Steven Feldman, Partner and Chair - White Collar Criminal Defense, Investigations & Compliance, STRADLEY RONON
• Rich Kando, Partner & Managing Director, ALIXPARTNERS
• Thomas Melvin, Partner, ALIXPARTNERS [Moderator]

 

TIME:
8:30 – 9:00 AM Check-in
9:00 – 10:15 AM Discussion
10:15 – 10:30 AM Networking

 

REGISTRATION FEE:
> EACCNY Members: Free
> EACCNY non-Members: Free

 

Note: This program is offered as an in-person event and will not be live-streamed or recorded.

 

Registration is closing at 2pm ET on October 21st, 2025.