Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past month, with links to primary resources. This month we ask: How have United States enforcement agencies reacted to President Trump’s executive order to pause enforcement of the Foreign Corrupt Practices Act (FCPA)? Which leading European enforcement agencies announced stepped-up efforts to combat foreign bribery? What new foreign bribery scandal has rocked the European Parliament? The answers to these questions and more are here in our March 2025 Top 10.
1. SEC to Follow DOJ’s Lead on FCPA Enforcement
On March 5, 2025, Antonia Apps, acting deputy director of the Security and Exchange Commission’s (SEC) Enforcement Division, stated that the agency plans to “follow the lead” of the Department of Justice (DOJ) in pausing enforcement of the FCPA. This is not surprising. Although President Trump’s February 2025 Executive Order titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security” (“Pause Order”) applied only to DOJ, we noted in our client alert that “it seems likely that some measures will be attempted to bring SEC’s enforcement in line with the Trump administration position[.]” Even if not surprising, SEC’s FCPA enforcement pause is significant: the agency has brought 276 civil enforcement actions involving foreign bribery allegations since 1977, including nine enforcement actions in 2024.
2. FCPA Trials Postponed Following Executive Order
In March 2025, several FCPA trials were postponed to allow DOJ to consider whether they should proceed under the Pause Order, which, among other things, directed the Attorney General to review in detail all existing FCPA investigations or enforcement actions with an eye to “restor[ing] proper bounds on FCPA enforcement and preserv[ing] Presidential foreign policy prerogatives[.]” On March 6, 2025, the trial of a former coal executive, whose arrest for allegedly bribing Egyptian officials to secure coal contracts with an Egyptian state-owned company was announced in March 2022, was stayed without a new trial date being set.[1] On March 11, 2025, the trial of two former technology-company executives, who were accused in February 2019 of authorizing an Indian construction company to bribe Indian government officials, was postponed for 30 days.[2] (The court in that case rejected DOJ’s request for a 180-day continuance, noting that the Attorney General had already completed a review of the matter and decided to proceed.) On March 24, 2025, the trial of three defendants, whom DOJ announced in December 2023 were charged in connection with an alleged scheme to bribe Honduran government officials to secure contracts to provide uniforms and other goods to the Honduran National Police, was postponed to August 2025.[3]
3. DOJ Terminates Swiss Commodities Trader’s FCPA Monitorship 15 Months Early
On March 19, 2025, DOJ released Glencore International A.G. from its compliance monitorship 15 months ahead of schedule. DOJ announced in May 2022 that the company had agreed to plead guilty to one count of conspiracy to violate the FCPA in connection with alleged schemes to bribe officials in Brazil, Cameroon, the Democratic Republic of Congo, Equatorial Guinea, Ivory Coast, Nigeria, and Venezuela in order to gain business advantages such as obtaining favorable terms from national oil companies and reducing liabilities related to government audits. According to a consent motion filed in the Southern District of New York, DOJ stated that it “has assessed the facts and circumstances of the case and determined to exercise the Government’s sole discretion under the Plea Agreement to terminate the monitorship early.”[4] The consent motion does not provide any further explanation for DOJ’s decision, but it seems likely that the early termination is related to the Pause Order. DOJ’s decision came just one day after the company disclosed in its annual report that New Jersey’s Economic Crime and Confiscation Unit was investigating the company.
4. Deputy Attorney General Proposes Reduction in DOJ FCPA Unit Personnel
On March 25, 2025, the Deputy Attorney General (DAG) issued a memorandum soliciting feedback from the heads of DOJ components on a proposed Agency Reorganization Plan and Reduction in Force (RIF). The plan was submitted pursuant to President Trump’s February 2025 Executive Order titled “Implementing the President’s ‘Department of Government Efficiency’ Cost Efficiency Initiative.” Among other things, the DAG memo proposes to “reduc[e] the number of attorneys assigned to [the DOJ Criminal Division’s] Fraud Section focused on FCPA matters[.]” Combined with the Pause Order, which, among other things, directs the Attorney General to issue updated guidelines or policies for FCPA enforcement, the proposed reduction in prosecutors suggests that the scope of FCPA enforcement will be narrowed, although how much remains to be seen. DOJ components have until April 2, 2025, to provide their feedback on the proposed changes. On March 30, 2025, Ranking Member of the House Judiciary Committee, Jamie Raskin (D-Md.), criticized the DAG’s proposal, including the proposed reduction of FCPA Unit prosecutors. Raskin stated, “Trump is incapacitating the DOJ unit prosecuting violations of the Foreign Corrupt Practices Act, giving the green light for criminal bribes, payoffs and kickbacks that had been forbidden for decades.”
5. Swiss Bank Successfully Completes FIFA-Related DPA
On March 17, 2025, Swiss bank Julius Baer & Co. Ltd. announced in its annual report that it had successfully completed its three-year deferred prosecution agreement (DPA). In May 2021, DOJ announced that the bank had entered into the DPA relating to the laundering of bribes allegedly paid to officials with the Fédération Internationale de Football Association (FIFA) and other soccer federations, between February 2013 and May 2015.
6. Three European Enforcement Agencies Form International Anti-Corruption Prosecutorial Taskforce
On March 20, 2025, the United Kingdom’s Serious Fraud Office (SFO), France’s Parquet National Financier (PNF), and Switzerland’s Office of the Attorney General (OAG) announced the formation of the International Anti-Corruption Prosecutorial Taskforce with the signing of a founding statement in London. The initiative establishes a formal collaborative framework to strengthen the agencies’ collective efforts against international bribery and corruption through a Leaders’ Group focused on strategy exchange and a Working Group dedicated to case cooperation. The taskforce aims to facilitate increased best practice sharing, seize opportunities for operational collaboration, and extend future membership to other like-minded anti-corruption agencies. Although SFO Director Nick Ephgrave stated that the initiative is “in no way a reaction” to the Pause Order, the timing of the announcement is nevertheless significant, as it suggests that three of the most significant non-U.S. foreign bribery enforcement agencies intend to step up their efforts.
7. Belgian Prosecutors File Corruption Charges in European Parliament Probe Involving Chinese Telecommunications Company
On March 18, 2025, Belgian state prosecutors announced that four people had been charged with corruption and criminal organization, and a fifth person with money laundering, as part of an alleged European Parliament cash-for-influence scheme involving Huawei. Prosecutors stated that three more defendants were charged between March 20 and 29, 2025. According to prosecutors and other reporting, beginning in 2021, up to 15 current and former members of the European Parliament (MEPs) received gifts from the company, such as smartphones, soccer tickets, or wire transfers, in exchange for taking political positions. The five original defendants were first detained on March 17, 2025, when police officers conducted searches of more than 20 locations in Belgium and Portugal, including the company’s Brussels offices. Earlier, on March 13, 2025, searches were conducted at offices in the European Parliament. On March 14, 2025, the European Parliament banned the company’s lobbyists from entering its premises “as a precautionary measure.” European Parliament President Roberta Metsola credited rules put in place as a result of “Qatargate” as leading to the detection of the alleged corruption, while critics argued that the new allegations demonstrate the inadequacy of the Parliament’s response to that scandal, which involved allegations that Qatar and Morocco paid a number of MEPs and other officials in exchange for legislative support.
8. OECD Working Group on Bribery Praises Belgium’s Legislative Reforms but Expresses Concern over Its Foreign Bribery Enforcement Results
On March 25, 2025, the Organization for Economic Cooperation and Development (OECD) Working Group on Bribery announced the results of its Phase 4 evaluation of Belgium’s implementation of the OECD Anti-Bribery Convention. All parties to the Convention are subject to a rigorous peer-review process, Phase 4 of which focuses on the evaluated country’s enforcement of the Convention and considers the country’s particular challenges and positive achievements. The Working Group found that Belgium had extended its statute of limitations for bribery offenses, ensured that corporate liability is no longer conditional on the prosecution or conviction of natural persons, extended its jurisdiction over foreign bribery offenses committed abroad, and adopted a whistleblower protection regime that reflects international standards and incorporates several best practices. The Working Group expressed concern, however, that only three foreign bribery cases had been successfully completed since the Phase 3 evaluation in 2013 and that no companies had been sanctioned during that period. The Working Group also found that Belgium does not effectively incentivize voluntary self-disclosures or the implementation of corporate anti-corruption compliance programs.
9. OECD Working Group on Bribery Finds Mixed Progress in Spain’s Anti-Corruption Enforcement Efforts
On March 25, 2025, the OECD Working Group on Bribery released its Phase 4 follow-up report on Spain. The Working Group found that Spain had diversified its sources for detecting foreign bribery, enacted a whistleblower protection law, and raised awareness of foreign bribery among Spanish officials, accountants, and auditors. The Working Group expressed concern, however, that Spain had not implemented several of the recommendations from the Phase 4 report and that overall enforcement remains low, even though two foreign bribery cases had been concluded since the Phase 4 report.
10. World Bank Debars Italian Aquaculture Company and Director for Corruption in Montenegro Project
On March 19, 2025, the World Bank Group announced a two-year debarment with conditional release of Panaque, S.R.L., and its sole director, Oscar Di Santo, for “collusive, fraudulent, and corrupt practices” connected to a Montenegro agricultural development project. According to the World Bank, between 2019 and 2020, Panaque and Di Santo had access to confidential information and helped prepare aspects of a tender that the company subsequently bid for and won, creating an undisclosed conflict of interest, and later made an improper payment to a public official during contract execution. The debarment, which followed a settlement agreement acknowledging responsibility, received a reduced period due to the parties’ “minor role in the misconduct, compliance efforts, cooperation, acceptance of responsibility, and voluntary restraint from seeking additional Bank Group-financed contracts.” As conditions for release, Panaque must implement integrity compliance measures reflecting Bank Group Compliance Guidelines, and Di Santo must complete corporate ethics training, with both committing to continued cooperation with the World Bank’s Integrity Vice Presidency. The sanctions qualify for cross-debarment by other multilateral development banks under the Agreement for Mutual Enforcement of Debarment Decisions, effectively blocking the company from participating in projects funded by major international financial institutions during the debarment period.
[1] Order, United States v. Hobson, Case No. 22-cr-00086, ECF No. 102 (W.D. Pa. Mar. 6, 2025).
[2] Order, United States v. Coburn, et al., Case No. 19-cr-0120-MEF, ECF No. 1003 (D.N.J. Mar. 11, 2025).
[3] Joint Motion to Continue Trial, United States v. Zaglin, et al., Case No. 23-cr-20454-JB, ECF No. 115 (S.D. Fla. Nov. 28, 2023).
[4] Consent Motion to Modify Conditions of Probation, United States v. Glencore International A.G., Case No. 1:22-cr-00297-LGS, ECF No. 62 (S.D.N.Y. Mar. 19, 2025).
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