Anti-Bribery Compliance in 2025: Key Global Updates

U.S. Anti-Bribery Compliance

As U.S. enforcement policies shift, businesses must navigate uncertainty in anti-bribery compliance. While the FCPA remains law, a potential slowdown in enforcement raises critical questions — but non-compliance is still a high-stakes risk.

Foreign Corrupt Practices Act (FCPA)

The Foreign Corrupt Practices Act (FCPA) has long been the cornerstone of U.S. anti-bribery enforcement, with regulators aggressively pursuing violations across industries and jurisdictions. However, the recent “review of enforcement” has sent shockwaves through the compliance world.

A slowdown in FCPA enforcement signals a potential shift in priorities, but it does not mean the law has lost its teeth. Companies that assume lower enforcement means lower risk may find themselves dangerously exposed when priorities shift again.

The FCPA covers:

• Bribery of Foreign Officials: Prohibits offering anything of value to foreign officials to gain business advantages.
• Accounting Transparency: Requires companies to maintain accurate books and internal controls to prevent corrupt payments.
• Global Reach: Applies to U.S. businesses and any foreign company that trades on U.S. exchanges or has operations in the U.S.

The SEC still retains civil enforcement authority over the FCPA, meaning companies remain at risk of investigations and penalties even if criminal prosecutions decline. Additionally, the FCPA’s six-year statute of limitations extends beyond the current administration, meaning that companies can still face enforcement actions long after policies change. FCPA violations continue to carry significant financial penalties, reputational damage, and the risk of criminal liability.

Foreign Extortion Prevention Act (FEPA)

At the same time, the Foreign Extortion Prevention Act (FEPA) — which criminalizes the demand side of bribery by foreign officials — introduces a new layer of complexity. While the FCPA has historically targeted companies and individuals paying bribes, FEPA aims to hold foreign officials accountable for soliciting bribes.

Key takeaways from FEPA:

• Targets Bribery Solicitation: Foreign officials who demand or accept bribes can now face legal action, strengthening global enforcement.
• Expands U.S. Enforcement: Closes a major gap by holding both sides of bribery accountable.
• Raises Corporate Risk: Companies may need to navigate complex diplomatic and legal challenges when dealing with foreign officials.

The combined force of the FCPA and FEPA means companies must remain vigilant, strengthen due diligence, and reinforce ethical business practices to mitigate risk both domestically and globally.

Asia-Pacific Anti-Bribery Compliance

As global enforcement patterns shift, the Asia-Pacific region continues to tighten anti-bribery and corruption laws, reinforcing corporate accountability and financial transparency.

Singapore’s Corporate Service Providers Act (CSP)

In Singapore, recent amendments to anti-bribery and financial crime laws reflect a tougher stance on corporate misconduct. The Corporate Service Providers (CSP) Act and the Companies, Limited Liability Partnerships, and Other Bodies (Miscellaneous Amendments) Act (CLLPMA) introduce stricter regulations for corporate service providers, focusing on anti-bribery, corruption, and money laundering. These laws aim to increase transparency, enhance due diligence requirements, and strengthen enforcement measures, ensuring that businesses operating in Singapore uphold high compliance standards.

Key Provisions from the CSP:

• Stricter Licensing Rules: Requires all corporate service providers to be registered and meet compliance standards.
• Enhanced Due Diligence: Mandates stronger checks on clients to prevent money laundering and illicit activities.
• Tighter Regulatory Oversight: Expands enforcement powers to monitor and penalize non-compliance.

India’s Prevention of Corruption Act (PCA)

Meanwhile, India’s Prevention of Corruption Act (PCA) continues to be actively enforced, with authorities ramping up investigations into both public and private sector corruption. The law criminalizes bribery in both giving and receiving illicit payments, and recent high-profile enforcement actions signal a commitment to cracking down on corporate corruption. With increased scrutiny on foreign companies operating in India, businesses must ensure robust internal controls, third-party due diligence, and whistleblower mechanisms to mitigate bribery risks.

Key Takeaways from the PCA:

• Global Enforcement Reach: Strengthens India’s alignment with international anti-corruption frameworks.
• Burden of Proof Shift: Requires accused individuals and businesses to prove their innocence.
• Corporate Liability: Holds companies accountable for failing to prevent bribery within their operations.
• Stricter Penalties: Increases fines and prison terms for corruption-related offenses.

• Reviewing and updating your anti-bribery policies to align with evolving regulations.
• Enhancing employee training to reinforce ethical decision-making.
• Strengthening ethics hotlines to encourage confidential reporting.
• Bolstering third-party due diligence to mitigate bribery risks in your vendor ecosystem.

Anti-Bribery Compliance is a Non-Negotiable