Senator Christopher Coons (D-DE) has a law degree from Yale. He previously worked as in-house counsel for a large company.
Senator Coons was a key participant in the Senate’s November 2011 hearing on “Examining Enforcement of the Foreign Corrupt Practices Act.”
During the hearing he stated.
“I have some personal experience from private practice in exactly this issue. Working for an excellent company, trying to deliver good compliance was, at times, a challenge, because of the moving target of knowing exactly what the compliance standards were. This was a number of years ago. Your advisory opinions, I think, have helped significantly. But I think we will listen attentively to the other panels for some clarity about what the current challenges are and would welcome an opportunity to continue to work with you and the department on helping clarify exactly what constitutes good compliance so that in-house counsel can sleep at night and compliant companies can more actively and effectively export.”
Senator Coons also stated:
“I would welcome an opportunity to work with the Committee on potential amendments to the act that would allow clarification on the definition of foreign official, the creation of a compliance defense.”
After the hearing, on January 10, 2011 I had a conference call with aides for Senator Coons and Senator Amy Klobuchar regarding FCPA reform including a compliance defense.
In short, Senator Coons, as a lawyer and Senator who once expressed an interest in FCPA reform, should be well-versed on FCPA topics.
As highlighted in this post, recently various Democratic Senators – including Senator Coons – introduced a short bill titled “The FCPA Reinforcement Act” seeking to extend the statute of limitations going forward for criminal FCPA anti-bribery offenses to ten years. (See this post for additional analysis).
Thereafter, Senator Coons issued this press release in which he states, among other things:
“It’s no surprise that the most corrupt administration in American history isn’t enforcing our corporate anti-corruption laws.”
Senator Coons: you can’t be serious.
In August 2025, there was a $4.7 million corporate FCPA enforcement action.
In October 2025, a company was criminally charged with conspiracy to violate the FCPA’s anti-bribery provisions, money laundering conspiracy, and money laundering.
In November 2025, there was a $118 million corporate FCPA enforcement action (see here and here).
As to FCPA enforcement against individuals, in September 2025, there was an FCPA trial. In December 2025, there was an FCPA trial. In February 2026, there was an FCPA trial. Post-trial activity continues in some of these matters in which the DOJ remains steadfast in its positions.
Another FCPA trial is scheduled to begin in August.
Earlier this month, a few days prior to Senator Coon’s press release, the DOJ brought a notable FCPA enforcement action against individuals. (See here).
But yet, Senator Coon’s maintains that the Trump administration “isn’t enforcing our corporate anti-corruption laws.”
Senator Coons: you can’t be serious.
