Why compliance efforts continue despite regulatory pullback

Global fight against corruption

• Other countries have their own anti-corruption regulations that still apply to US institutions due to the regulations’ extraterritorial reach, including the United Kingdom’s Bribery Act and Brazil’s Anti-Corruption Law. In recent times, US companies have been found liable under these laws as a result of their operations there — and financial institutions are particularly at risk due to the global reach of their operations and the connectivity within the financial services industry.
• The past few years have seen significant international cooperation in the global fight against corruption, with cross-jurisdictional investigations and information sharing between regulatory bodies. This is expected to continue — whether the US is part of it or not. The United Kingdom recently outlined the objective to become a “proactive, authoritative player in the global and domestic justice system” in a regulatory filing.
• In March 2025, regulators from the United Kingdom, France and Switzerland announced the formation of the International Anti-Corruption Prosecutorial Taskforce to strengthen collaboration in the fight against bribery and corruption.

Positive impacts of ABC programs

ABC programs are a key tool that help financial institutions combat corruption and fraud

• Bribery and corruption undoubtedly have a negative impact on an organization’s reputation, which in turn can affect well-established client and stakeholder relationships. Having a strong and active ABC program protects against this risk.
• An effective ABC program has proven value as illicit activity undermines the integrity of the organization and may signal a weakness of internal controls, leading to the risk of less ethical conduct and other wrongdoing and fraud across the entity.
• There is expected to be a focus from the US government on illicit activities of criminal gangs, cartels and enterprises. Effective ABC policies executed in conjunction with anti-money laundering (AML) policies will be key levers for financial institutions to demonstrate to regulators their efforts to combat the activities of these criminal gangs and enterprises.

FCPA statute of limitations

Companies should not lose sight of the FCPA statute of limitations

Organizations must remain cognizant that FCPA violations may still be subject to future prosecution. The FCPA’s statute of limitations may present opportunities for future prosecution and be applicable as enforcement priorities evolve.

• Unpredictability of the 180-day time frame:
  • It remains to be seen if this review period will be extended, as it is up to the discretion of the Attorney General. If the 180-day pause is extended, this period of uncertainty may continue as companies navigate the evolving regulatory environment.
  • The statute of limitations will remain relevant regardless of future actions, as its repeal would require formal action by Congress. There is currently no indication that this is being considered.