When President Donald Trump issued his executive order pausing enforcement of the FCPA, many practitioners were taken by surprise. Now that the dust has settled some, and pending further guidance from AG Pam Bondi on what enforcement will look like going forward, it is time for companies to decide how to react, if at all, to the news. The Anti-Corruption Report spoke with numerous practitioners – both on and off the record – to understand the current state of play and whether companies should adjust their compliance programs. This first article in a two-part series examines the ways that U.S. enforcement will be impacted, both in the near term and further down the line. The second article will cover international enforcement and whether companies should pull back on compliance. Spoiler alert: they should not. See “Executive Order Presses Pause on FCPA Enforcement” (Feb. 12, 2025).