With President Donald Trump’s executive order hitting pause on the Department of Justice’s enforcement of the Foreign Corrupt Practices Act, Bracewell’s Nicole Boeckmann, Mark Hunting and Meg Beasley share their perspective with Corporate Compliance Insights in a Q&A on this complex issue.
On how companies should adjust their existing FCPA compliance programs during this 180-day enforcement pause, Boeckmann, Hunting and Beasley shared that “[I]rrespective of how the DOJ approaches the FCPA for the next four years, the statute of limitations will outrun President Trump’s term: Criminal and civil violations of the FCPA’s anti-bribery provisions have a five-year statute of limitations, and criminal violations of the books and records and internal controls provisions have a six-year statute of limitations.”
