This is the third post on this topic (see here and here).

In February 2025, President Trump issued an Executive Order “pausing” DOJ FCPA enforcement.

The “pause” lasted a relatively brief 118 days during which various aspects of FCPA (and related) enforcement continued.

The “pause” ended over seven months ago and since then DOJ FCPA enforcement has continued.

In fact, corporate DOJ FCPA enforcement in 2025 exceeded corporate DOJ FCPA enforcement in 2021 and 2015 and the current period is one of the most active periods in FCPA history in terms of FCPA trials.

Yet, various actors continue to mention the “pause” seemingly to advance various narratives – while failing to mention the above facts.

For instance, yesterday Rep. Jamie Raskin, Ranking Member of the House Judiciary Committee, delivered opening remarks at the Subcommittee on Crime and Federal Government Surveillance hearing on “Republicans’ selective concern about fraud, as they stay silent while Trump pardons fraudsters, guts oversight and enriches himself from the Oval Office—harming all Americans.”

Rep. Raskin stated:

“[H]is [Trump’s] DOJ suspended enforcement of the Foreign Corrupt Practices Act, which prohibits foreign bribery, saying all bets are off.”

No mention of the above facts.

Transparency International recently published this piece titled “Is the United States Still a Global Leader in the Fight Against Corruption” which states:

“We encouraged the [Trump] administration to reactive the Foreign Corrupt Practices Act. However, threats remain. To be effective, laws need to be robust, properly enforced, and impartially applied.”

Again, no mention of the above facts.

That’s not very transparent coming from Transparency International.

The question thus again arises: what is the “shelf life” of the “pause.”

Will media coverage and various commentators continue to mention the “pause” throughout 2026, 2027, 2028, etc. seemingly to advance various substantive assertions – while at the same time failing to mention the above facts?

Time will tell.

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