Call me old-fashioned, but when one voluntarily puts information into the public domain on a specific topic (in this case a specific law and its enforcement) there is an obligation to be accurate.
However, there is lots of rubbish in the FCPA space. Individuals (whether paid journalists or individuals who portray themselves as compliance and ethics professionals) who pollute the public domain with false or misleading information.
I didn’t invent fact-checking, I just sometimes do it in the FCPA context. And, I encourage people to do the same to me. I want to be held accountable for the things I write.
Some recent examples of FCPA rubbish.
Talking Points Memo (TPM) states that one of its goals is “do good journalism” with a goal of “accuracy, fairness and a fundamental honesty with our readers and members at all times.”
David Kurtz is TPM’s Editor at Large.
In an April 14th article, he states: “Under Trump II, the DOJ has explicitly stopped enforcing the Foreign Corrupt Practices Act.”
This is false.
Since August 2025, there have been 9 DOJ FCPA enforcement actions (corporate or individual).
This April 16th article in the Dispatch (which markets itself as providing fact-based reporting and commentary) states: “acting Attorney General Todd Blanche announced a new National Fraud Enforcement Division that notably did not include the DOJ’s FCPA unit at all.”
But why would it?
As stated by the DOJ: “The core mission of the National Fraud Enforcement Division is to zealously investigate and prosecute those who steal or fraudulently misuse [U.S.] taxpayer dollars.”
Contrary to what the article says, there were not 22 “DOJ FCPA Enforcement Actions” in 2024.
Saying that “FCPA enforcement may be out of favor under the Trump administration” is interesting against the backdrop of 9 DOJ FCPA enforcement actions (corporate or individual) since August 2025.
The last statement is completely false.
Since August 2025, there have been 9 FCPA enforcement actions (corporate or individual).
