You are quoted in this article as recently stating that “the enforcement of the Foreign Corrupt Practices Act has been dismantled” under the Trump administration.
This is a false statement.
Given that your quote concerns a law and its enforcement, it is particularly egregious since you are a graduate of Harvard Law School and former editor of the Harvard Law Review.
For your benefit, I provide a brief overview of FCPA enforcement during the second Trump administration.
It is true, that on February 10, 2025 President Trump signed an Executive Order Titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.” As highlighted in this post, several of the substantive issues discussed in the Executive Order had been festering in the FCPA space (and openly discussed by politicians in both parties) for approximately 15-20 years prior.
The “pause” lasted a brief 118 days, during which certain aspects of FCPA or related enforcement actually continued (see here, here, here, here, here).
Since the “pause” ended in mid-June 2025, there have been several FCPA enforcement actions against business organizations or individuals and other FCPA or related developments.
In July 2025, the DOJ “defended” its positions in responding to a motion to dismiss filed by Carl Zaglin in a pending FCPA (and related) enforcement action concerning an alleged bribery scheme in Honduras. (See here). In September 2025, Zaglin was found guilty at trial. In December 2025, Zaglin was sentenced
In August 2025, Liberty Mutual resolved a $4.7 million FCPA enforcement action concerning conduct in India.
In August 2025, the DOJ criminally charged Ramon Alexandro Rovirosa Martinez and Mario Alberto Avila Lizarraga in connection with an alleged bribery scheme in Mexico. In December 2025, Roviorsa was found guilty at trial, post trial briefs were filed, and in April 2026 a federal court judge dismissed the case. In May 2026, the DOJ filed a notice of appeal and in September 2026 the DOJ filed its appellate brief.
In September 2025, a Nigerian “foreign official” was found guilty at trial in the U.S. of various criminal offenses in connection with bribery schemes.
In September 2025, Vikas Sagar was sentenced in connection with a pending FCPA enforcement action.
In September 2025, Smartmatic was criminally charged with FCPA and related offenses in connection with alleged bribery scheme in the Philippines and since then the DOJ has continued to actively prosecute the case.
In October 2025, Carlos Leopoldo Alvelais Alarcon pleaded guilty to FCPA offenses in connection with a bribery scheme in Mexico and he was sentenced in July 2026. Also in July 2026, and in connection with the same core conduct, Scoular resolved a $10.2 million FCPA enforcement action.
In November 2025, Millicom International Cellular S.A. and its subsidiary Comcel resolved a $118 million FCPA enforcement action in connection with a bribery scheme in Guatemala.
In December 2025, Glen Oztemel was sentenced in connection with an FCPA enforcement action involving conduct in Brazil. Oztemel has appealed to an appellate court and the DOJ has responded.
In February 2026, Charles Hunter Hobson was found guilty at trial in an FCPA enforcement action concerning an alleged bribery Scheme in Egypt. Post trial motions remain pending and the DOJ has objected to the motions.
In March 2026, the DOJ announced an FCPA enforcement action against David Ferrera and Marc Tilman in connection with an alleged bribery scheme in France and the DOJ continues to actively prosecute the case. Also in March 2026, and in connection with the same core action, Balt resolved a $1.2 million FCPA enforcement action.
In March 2026, the DOJ criminally charged Alfonso Wilson in connection with an bribery scheme in Mexico and he later pleaded guilty. In April 2026, in connection with the same core action, the DOJ unsealed a related FCPA enforcement action against Diego Bergonzi.
In April 2026 the DOJ filed a civil forfeiture action alleging that a U.S. defense contractor bribed a Kurdish official in connection with jet fuel contracts.
In June 2026, Abraham Cigarroa Cervantes pleaded guilty to FCPA offenses in connection with a bribery scheme in Brazil.
In June 2026, the DOJ posted job openings for attorneys in its FCPA Unit.
In August 2026, Asante Berko (a former Executive Director of Goldman Sachs International) was convicted by a jury of FCPA and related offenses in connection with a Ghana bribery scheme after a trial in New York.
As you can see Congressman Raskin, there has been numerous FCPA enforcement actions and related developments during the second Trump administration despite your claims that “the enforcement of the Foreign Corrupt Practices Act has been dismantled.”
In fact, in 2025 the were more DOJ FCPA enforcement actions against business organizations compared to certain prior years such as 2021 and 2015.
As to the several FCPA trials mentioned above, the past approximate year has been one of the most active periods of FCPA trials in the nearly 50 year history of the law.
Should you have any questions or concerns regarding the information in this post, I would be happy to chat.
Kind Regards
