Don't Wait for the Knock: Right-Sizing Compliance in a Shifting Enforcement Landscape

22 October 2025

As compliance professionals have observed, recent shifts in U.S. corporate enforcement priorities have altered the risk landscape for multinationals both foreign and domestic. We discussed in June 2025 one key component of this shift: the U.S. Department of Justice's new "Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)," the marquee American foreign bribery law. On top of this development, a slew of other recent policies and guidelines have ramped up the pressure on multinationals to right-size their compliance programs to ensure that they adequately meet these new enforcement priorities and expectations.

Download PDF