Earlier this week, this post posed the question “what is the ‘shelf life’ of the pause.”

The post noted that certain media coverage continues to mention the “pause” seemingly to advance various substantive assertions – all while failing to mention that the “pause” was brief, ended over six months ago, and FCPA enforcement has continued (in fact at a pace exceeding certain prior years such as 2021 and 2015).

I wasn’t anticipating publishing the same general post again this week, but the coverage continues.

For instance, this article (dated December 18th) by Frank Mora (Professor of Politics and International Relations and Senior Research Scientist at the Jack D. Gordon Institute for Public Policy, Florida International University) is titled: “Anti-Corruption: A Missing Element in Trump’s Latin America Policy” and contains the byline: “the administration’s decision not to enforce the Foreign Corrupt Practices Act, among other choices, risks long-term damage to the region.”

The article states:

“The consequences are visible across multiple fronts. First is the administration’s reduced enforcement of the Foreign Corrupt Practices Act (FCPA), the most important U.S. legal tool for deterring corporate bribery abroad. For years, strong FCPA enforcement not only helped U.S. companies compete fairly but signaled that the United States was committed to strengthening clean governance globally.

Now, enforcement actions have declined sharply after the president’s February 10, 2025 executive order directing the attorney general to “cease initiation of any new FCPA investigations or enforcement actions.”

Either Mora is unaware that the so-called 118 “pause” ended over six months ago and that FCPA enforcement has resumed (at a pace exceeding certain prior years such as 2021 and 2015) or he is aware of these issues but just chooses to ignore them.

Either instance is troubling.

Mora’s article also fails to mention that the past few months have been one of the most active periods of FCPA trials in approximately 50 years. An individual was convicted of FCPA offenses at trial in September and another individual was convicted at trial this month. In fact, both trials involved conduct in countries the focus of Mora’s article. In addition, two additional FCPA trials are scheduled for early 2026.

Once again, the question arises: what is the “shelf life” of the “pause.”

Will media coverage and various commentators continue to mention the “pause” in 2026, 2027, 2028, etc. seemingly to advance various substantive assertions – while at the same time failing to mention that the “pause” was brief, ended, and FCPA enforcement has resumed?

Time will tell.

But then again, the apparent “shelf life” of honey is forever.