In February 2025, President Trump “paused” DOJ FCPA enforcement.
The “pause” lasted a relatively brief 118 days during which various aspects of FCPA (and related) enforcement continued.
The “pause” ended over six months ago and since DOJ FCPA enforcement has continued. In fact, corporate DOJ FCPA enforcement in 2025 exceeds corporate DOJ FCPA enforcement in 2015 and 2021 and the current period is one of the most active periods in FCPA history in terms of FCPA trials as two trials occurred in the past four months and two additional trials are scheduled for early 2026.
Yet, certain media coverage continues to mention the “pause” seemingly to advance various substantive assertions – all while failing to mention that the “pause” was brief and ended over six months ago.
The question thus arises: what is the “shelf life” of the “pause.”
Will media coverage and various commentators continue to mention the “pause” in 2026, 2027, 2028, etc. seemingly to advance various substantive assertions – while at the same time failing to mention that the “pause” was brief and ended?
Time will tell.
But then again, the apparent “shelf life” of honey is forever.
