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US white-collar enforcement trends mid-2025: FCPA narrowing, enhanced voluntary self-disclosure, crypto shift, clemency-driven defence strategies, and a weakened federal public corruption programme

Published on: 27 June 2025

Published by a Law360 reporter
Legal News
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Article summary

Yet questions persist about what lies ahead for several core enforcement fronts, from foreign bribery and public corruption to crypto. White-collar practitioners and their clients are also monitoring the government’s renewed bid to incentivise voluntary self-reporting of corporate misconduct and how it unfolds in the months ahead. Concurrently, the white-collar bar across the profession is crafting fresh defence tactics in response to a spate of Trump clemency decisions that aided certain high-profile offenders found guilty of corruption and financial offences. Below are five pivotal themes to watch as the latter half of 2025 develops.

FCPA enforcement

Within a month of re-entering the White House, President Donald Trump also halted enforcement of the Foreign Corrupt Practices Act (FCPA) to, in his words, ‘further American economic and national security’. The step fuelled predictions that FCPA policing would be sharply reduced at the time. However, a 9 June 2025 memo from Deputy US Attorney General Todd Blanche indicated a potential return to ‘business as usual’ for FCPA work, according to Marisa Darden, chair of the white-collar, government investigations and regulatory practice at Benesch Friedlander Coplan & Aronoff LLP, speaking to Law360. Blanche’s memorandum set out slightly tighter parameters at this juncture for the...

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