/>iApproximately two weeks ago, British, French and Swiss law enforcement authorities announced the creation of a new international alliance. With their joint Founding Statement (“Statement”), the three countries established the International Anti-Corruption Prosecutorial Taskforce (“Taskforce”) to tackle the threat of bribery and corruption. Though statements made by one of the three signing officials note that the launch of this new organization is “in no way a reaction to” the recent US pause on Foreign Corrupt Practices Act (“FCPA”) enforcement, the timing of this debut coupled with the conspicuously absent American presence from the taskforce suggests otherwise.
The nascent organization was launched on March 20, 2025, via a collective statement promulgated by the United Kingdom’s Serious Fraud Office, France’s Parquet National Financier, and the Office of the Attorney General of Switzerland. The Statement succinctly sets out the Taskforce’s aims in a single page. Beginning by recognizing the “significant threat of bribery and corruption and the severe harm that it causes,” the Statement then reaffirms its commitment to tackling such. It subsequently sets out two subgroups that will be formed: a “Leaders’ Group” that will focus on “the regular exchange of insight and strategy” and a “Working Group” that will “devis[e] proposals for co-operation on cases.” This is intended to strengthen cooperation and will also involve enhanced operational exchanges in the handling of individual cases, as well as the development of a broader framework for reflection on international anti-corruption strategy. The Statement concludes by extending an open invitation for other “like-minded agencies involved in tackling international bribery and corruption to join the Taskforce.”
Given the short timespan between the birth of this international organization and the Trump administration’s recent policy changes pausing FCPA enforcement, there has been a good deal of speculation that these two developments bear some relation to one another.
The policy changes related to FCPA-related prosecution began with a memorandum issued by U.S. Attorney General Pam Bondi on February 5, 2025 — the same day that she was sworn in. In one of her fourteen “Day One” memos, she stated that “[t]he Criminal Division’s Foreign Corrupt Practices Act Unit shall prioritize investigations related to foreign bribery that facilitate[] the criminal operations of Cartels and TCOs, and shift focus away from investigations and cases that do not involve such a connection.”
On February 10, 2025, President Trump followed up by issuing Executive Order 14209 (“Order”), “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security,” in which he implemented a 180-day “review period” during which — among other items — no new FCPA investigations or enforcement actions may be brought barring the approval of the Attorney General. During this time, all current FCPA investigations or enforcement actions are also under scrutiny, as the Order notes that “appropriate action” will be taken with respect to existing matters “to restore proper bounds on FCPA enforcement.” The Order also provides for an additional 180-day extension to this review period should the Attorney General deem it appropriate.
Though the newly formed Taskforce has yet to take any affirmative steps since its inception, its very creation has signaled European dissent from President Trump’s policy shift regarding the FCPA prosecution. Despite a recent shift in American prosecution away from FCPA matters, businesses should still take precautions to remain in compliance with all applicable laws or risk facing consequences from any number of regulators — at home or abroad.
