Hughes Hubbard Releases the 2025 FCPA Alert

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Jan. 21, 2026 – Hughes Hubbard has released its 2025 FCPA & Anti-Bribery Alert. For the 17th consecutive year, this highly respected and anticipated resource provides in-house counsel and compliance professionals with a comprehensive analysis of the year’s most significant trends, enforcement actions and policy developments in anti-bribery law, as well as an encyclopedic view of the past year’s enforcement actions and policy updates related to the Foreign Corrupt Practices Act (FCPA), and anti-bribery developments in Brazil, France and the UK, and at multi-national development banks.

The 2025 alert covers a year of unprecedented change, including the Trump Administration’s temporary pause on FCPA enforcement, the subsequent introduction of new Department of Justice enforcement guidelines, and the evolving priorities of U.S. and international authorities. The alert offers in-depth analysis of the revised DOJ Corporate Enforcement and Voluntary Self-Disclosure Policy, changes to monitorship standards and the expansion of the DOJ’s whistleblower program.

With these and other developments as context, the alert provides forward-looking guidance for corporations and individuals navigating the updated landscape. This includes considerations regarding:

• Pre-acquisition anti-corruption due diligence and integration planning in the context of corporate M&A;
• Appropriate due diligence and monitoring of business partners;
• The broad interpretation of “internal accounting controls” as used in relevant FCPA provisions;
• Donations, sponsorships, gifts and hospitality; and
• Policies surrounding personal device use, messaging applications, and balancing data protection with compliance needs.

With practical insights and detailed analysis, the 2025 FCPA & Anti-Bribery Alert is an essential resource for staying ahead in a rapidly changing enforcement environment.

For more information or to request a physical copy of the alert, please contact Michael A. DeBernardis, Chair of the U.S. Global Investigations, Enforcement, and Compliance Practice, at [email protected].