Article | June 30, 2026
FCPA Enforcement: Where the Bribery Actually Happened
FCPA enforcement trends analyzed by geography. Discover where bribery risk is concentrated and how it impacts global compliance, investigations and risk management.
This article first appeared on Law360 on June 5, 2025.
Shifting trade policies, escalating tariffs, and evolving export controls are intensifying financial reporting and compliance risks for public companies. In the current enforcement landscape, companies face heightened scrutiny from both the SEC and DOJ around how they identify, manage, and disclose the impact of international trade disruption. Missteps such as downplaying real risks, concealing costs associated with sanctions, or failing to maintain strong internal controls can lead to significant legal and reputational consequences.
In a recent Law360 article, Jennifer Lee of Jenner & Block and Edward Westerman of Secretariat examine how trade uncertainty is no longer just a geopolitical issue but a material financial reporting risk. They outline the critical areas where public companies must focus, including improving transparency, strengthening compliance programs, and anticipating regulator expectations. As enforcement agencies sharpen their focus, the ability to align disclosure, governance, and internal controls has never been more important.
Secretariat Managing Directors John Rademacher, Norman Harrison, and Jenner & Block Associate Rebekah Lee, contributed to this article.