Late on February 10, 2025, President Donald Trump signed an executive order (EO) “pausing” enforcement of the FCPA by the DOJ for at least 180 days to evaluate the current pipeline of cases and formulate new guidance and policies for future prosecutions. The reasoning behind the EO is at odds with Congress’ stated purposes for the FCPA and statements by DOJ officials under both the first Trump administration and the Biden administration. And it comes just after newly sworn in AG Pam Bondi delivered a memorandum addressing FCPA enforcement that conflicts with the EO in some ways. This article breaks down the EO and examines it in the context of enforcement history. Future Anti-Corruption Report content will provide insights from defense counsel and other experts in the field about what it means for companies. For further context, see “A Quick Look at 2024 Anti-Corruption Enforcement Developments” (Jan. 15, 2025).