FCPA Enforcement Has Shifted. Is Your Compliance Strategy Keeping Up?
In early 2025, the DOJ paused enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days. When enforcement resumed, the rules and the risks had changed.
This free expert guide, co-authored by Ground Truth Intelligence, Honigman, and Ericsson, breaks down the DOJ’s new priorities and how compliance, risk, and legal teams can adapt quickly.
What You’ll Learn:
- The three new enforcement priorities every compliance team must know
- How to update your risk profiles for cartel, infrastructure, and strategic sector exposure
- Practical steps to train your team and strengthen due diligence
- How AI-powered tools can help uncover hidden links and suspicious activity faster
- Why early self-reporting can mitigate penalties
Authors:
Matthew Hunt – Co-founder and COO @ Ground Truth Intelligence
Daniel Wendt – Partner @ Honigman
Janos Kuhn – Global Head of Customer & Third Party Compliance @ Ericsson
Ground Truth Intelligence is the global due diligence platform for a changing world. Our technology merges workflow and research tools with access to on-the-ground experts and critical risk data, helping you make faster, more informed, and more ethical business decisions.
FAQs
What are the DOJ’s new priorities for FCPA enforcement in 2025?
The DOJ has shifted its focus to cartel-linked corruption, infrastructure projects, and strategic sectors. Compliance teams must update risk assessments to account for these areas and adapt monitoring practices accordingly.
How can compliance teams adapt to the changing FCPA enforcement landscape?
Compliance officers should review and update risk profiles, enhance due diligence on high-risk third parties, and provide targeted training. Leveraging AI-powered tools can also improve the detection of hidden connections and suspicious activity.
Why is early self-reporting important under the revised FCPA approach?
The DOJ has emphasised that organisations demonstrating proactive self-reporting may face reduced penalties. This makes early detection and swift escalation of potential violations a critical component of an effective compliance strategy.
What role does technology play in strengthening FCPA compliance?
Modern compliance platforms, such as GTI, use AI and data integration to identify hidden risks faster, streamline due diligence, and support investigations. This enables legal and compliance teams to respond more quickly to evolving enforcement priorities.
Who should download the FCPA whitepaper?
The guide is designed for compliance, risk, and legal professionals responsible for anti-bribery and corruption oversight. It is particularly relevant for organisations exposed to international markets, high-risk sectors, or complex third-party networks.
How does this whitepaper help prepare organisations for enforcement changes?
It provides frameworks, expert insights, and real-world strategies to update compliance programmes. By following the guidance, organisations can strengthen internal controls and reduce exposure to financial and reputational risks.