14. Reuters. “Trump Loosens Enforcement of U.S. Law Banning Bribery of Foreign Officials.” February 10, 2025. https://www.reuters.com/world/us/trump-loosen-enforcement-us-law-banning-bribery-foreign-officials-2025-02-10/ Reports the executive order pausing FCPA enforcement pending new guidelines.
15. Transparency International. “Statement on the Suspension of FCPA Enforcement.” February 2025. https://www.transparency.org/en/press Pauses to FCPA enforcement “will harm economies and governance worldwide,” TI says.
16. Reuters. “US Justice Department Resumes Scaled-Back Enforcement Against Foreign Bribery.” June 10, 2025. https://www.reuters.com/business/finance/us-justice-department-resumes-scaled-back-enforcement-against-foreign-bribery-2025-06-10/ Details DOJ’s narrowed resumption of FCPA enforcement and new priorities.
17. Willkie Farr & Gallagher. “DOJ Issues New FCPA Enforcement Guidelines Focused on U.S. Interests.” Compliance Concourse, June 12, 2025. https://complianceconcourse.willkie.com/articles/doj-issues-new-fcpa-enforcement-guidelines-focused-on-u-s-economic-and-national-security-interests/ Client alert summarizing DOJ guidance and confirming enforcement has resumed.
18. U.S. Department of Justice. “Former Los Angeles City Councilmember José Huizar Sentenced to 13 Years for Corruption.” Press Release, April 12, 2024. https://www.justice.gov/usao-cdca/pr/ Excerpted quote: “Huizar sold out his city.”
19. U.S. Department of Justice. “Pittsburgh Building Inspector Pleads Guilty to Bribery.” Press Release, May 2024. https://www.justice.gov/usao-wdpa/pr Excerpted quote: “Whether it’s $200 or $200,000, a bribe is a bribe.”
20. Department for Business, Energy & Industrial Strategy (UK). Review of the Implementation of the PSC Register, March 2019. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/822823/psc-register-review.pdf BEIS review noting “All Law Enforcement Organisations we spoke to had used the PSC register…”
21. Skadden, Arps, Slate, Meagher & Flom LLP. “Foreign Extortion Prevention Act Criminalizes Demand-Side Bribery.” January 8, 2024. https://www.skadden.com/insights/publications/2024/01/foreign-extortion-prevention-act-criminalizes-demand-side-bribery Overview of FEPA, which targets the “demand side” of foreign bribery.
22. Transparency International. “CPI 2021: Trouble at the Top—U.S. Declines 9 Points Since 2015.” Transparency International, January 2022. https://www.transparency.org/en/news/cpi-2021-trouble-at-the-top Context for the U.S. historical slide from the mid-70s to the high-60s.
Bibliography
1. CPI figures and methodology are from TI’s official pages and report; the Supreme Court ethics code and its non-enforcement are documented by the Court’s PDF and CRS; ProPublica’s line on “luxury trips virtually every year” is verbatim; the CTA/FinCEN changes are drawn from FinCEN’s press release, Federal Register text, and guidance page; the FCPA pause and narrowed restart are covered by Reuters and summarized in a Willkie client alert; municipal case quotes come from DOJ press releases; the UK PSC register line is from BEIS’s post-implementation review; FEPA context is from legal summaries.