The suspension of the U.S. FCPA and its implications for U.S. affiliated entities operating in Asia

In February 2025, President Trump passed Executive Order 14209, which temporarily suspends criminal enforcement of the U.S. Foreign Corrupt Practices Act (“FCPA”) for at least 180 days, and directs the U.S. Department of Justice to review all existing FCPA investigations or enforcement actions, and issue updated guidelines or policies governing FCPA investigations or enforcement actions.

In this update, Director Gary Low and Senior Associate Victor David Lau examine how U.S. affiliated entities operating in Asia have historically managed FCPA compliance, the implications of Executive Order 14209 for U.S. affiliated entities operating in Asia, and highlight key lessons for U.S. affiliated entities continuing operations in Asia amid an evolving regulatory environment.

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