DOJ's FCPA Docket: What's Been Closed, What Continues and What Might That Tell Us for the Next Several Years?
Bribe, Swindle or Steal
Alexandra Addison-Wrage of TRACE International
4.9 • 582 Ratings
🗓️ 1 October 2025
⏱️ 21 minutes
🧾️ Download transcript
Summary
At the 2025 TRACE Annapolis Forum, Billy Jacobson, Partner at Jacobson Lopez, explores the DOJ's shifting FCPA priorities—from a focus on "grand corruption" and the costs of investigations to prosecutorial uncertainty and statutes of limitation. In today's unpredictable environment, companies must stay the course, protect resources, and invest in training.
Transcript
Click on a timestamp to play from that location
| 0:00.0 | Welcome back to the podcast, Bride, Swindle, or Steel. I'm Alexandra, Addison, Rogge, and today we're hearing from Billy Jacobson, of Jacobson Lopez, on the current FCPA docket, what's been closed, what remains open, and what this tells us about what to expect |
| 0:21.8 | over the next few years. |
| 0:23.5 | Billy gave this talk at the recent Trace Forum where, for the first time in over 20 years, |
| 0:28.2 | we weren't able to secure a Department of Justice Speaker. |
| 0:31.0 | Here's Billy. |
| 0:32.0 | Thanks, Alexandra. |
| 0:33.0 | So I'm going to address the Trump administration's approach to FCPA enforcement, and we'll try to break it down |
| 0:38.6 | and understand a little bit to the extent we can about what it means. First, let's revisit the |
| 0:44.5 | FCPA pause, which I'm sure you're all familiar with. A pause was issued by an executive order |
| 0:51.8 | on February 10th, 2025. By dint of the executive order, by the language of the executive order on February 10th, 2025. |
| 0:55.0 | By dint of the executive order, by the language of the executive order, |
| 0:58.0 | it would last six months with the possibility of renewing it another six months. |
| 1:02.0 | I think many of us at the time, but maybe it'll last the whole term, right? |
| 1:06.0 | Because if he, all he has to do is issue another executive order and the pause will keep lasting. |
| 1:10.0 | But to my surprise, I don't know if anyone else was surprised, but to my surprise, it only lasted about four months. The pause was lifted in June, so I think that was welcome news, welcome in sort of, you know, by the anti-corruption community. The executive order itself, though the pause has been lifted, I think it's worth exploring the executive order just a little bit, |
| 1:29.6 | because it lays the foundation for the policies that were and the guidelines that came into effect afterwards. |
| 1:34.5 | So the executive order says that over-expansant unpredictable FCPA enforcement against American citizens and businesses by our own government for routine |
| 1:46.3 | business practices in other nations, not only waste limited prosecutorial resources that could |
| 1:52.5 | be dedicated to preserving American freedoms, but actively harms American economic competitiveness |
| 1:58.5 | and national security. The EO required that during the pause, |
| 2:03.6 | the Justice Department do a few things. First, what it would not do. It would not initiate |
| 2:08.6 | any new cases unless the Attorney General granted an exception to that. Second, it would |
... |
Please login to see the full transcript.
Disclaimer: The podcast and artwork embedded on this page are from Alexandra Addison-Wrage of TRACE International, and are the property of its owner and not affiliated with or endorsed by Tapesearch.
Generated transcripts are the property of Alexandra Addison-Wrage of TRACE International and are distributed freely under the Fair Use doctrine. Transcripts generated by Tapesearch are not guaranteed to be accurate.
Copyright © Tapesearch 2026.